 While no previous cases had been brought by or against Satan and so no official precedent existed, there was an "unofficial account of a trial in New Hampshire where this defendant filed an action of mortgage foreclosure as plaintiff", a reference to the 1936 short story "The Devil and Daniel Webster" by Stephen Vincent Benét.Judge Weber suggested that the Devil (who had claimed in that story to be an American), should he appear, might have been therefore estopped from arguing a lack of personal jurisdiction.In this context, the Court noted that Satan was a foreign prince, but did not have occasion to address whether, if sued as a defendant, he would be able to claim sovereign immunity from suit.