Underhill v. Hernandez

American citizen Underhill (plaintiff) built and operated a water system in Venezuela under contract with the government, and after General Hernandez (defendant) led a coup that the U.S. subsequently recognized as Venezuela's legitimate government, Hernandez initially denied then later granted Underhill's request to leave the country; Underhill sued in U.S. federal court for illegal detention, and the court of appeals found the courts lacked jurisdiction since the acts occurred within a foreign sovereign's own territory.