was unnecessary to prevent the courts from interfering in affairs of state, as a single court could upset delicate international negotiations through the assertion of U.S. law in another country. Finally, the Court found no bar to application of the doctrine should be imposed by the fact that Cuba had brought the suit, comparing this to the sovereign immunity enjoyed by U.S. states which can sue, but can not be sued. The court also raised and dismissed a potential Erie doctrine problem, noting that although this suit was brought under diversity jurisdiction, federal interests so outweighed that of the state that federal common law must apply, instead of the law of the state where the suit was filed. White's dissent Justice White wrote a "dismayed" dissenting opinion, asserting that the court's application of the act of state doctrine was too rigid: more so, in fact than the doctrine as applied by other countries. Subsequent developments Not surprisingly, the Sabbatino case provoked an uproar in the U.S. Congress. Before the case could be reviewed by the district court (on remand), Congress passed the so-called Second Hickenlooper Amendment (or Sabbatino Amendment) that revoked this presumption in favor of the validity of the act of state doctrine that the Sabbatino court had established. The Amendment was retroactive and subsequently found constitutional by the district court and the Cuban bank's complaint was dismissed. This amendment to the Foreign Assistance Act has clarified that courts may proceed with an adjudication on the merits unless the President states that such adjudication may embarrass foreign policy efforts, but the amendment has been construed very narrowly by subsequent court decisions. References Further reading External links 1964 in United States case law United States Constitution Article Three case law United States foreign sovereign immunity case law United States Supreme Court cases United States Supreme Court cases of the Warren Court Cuba–United States relations