The Soviet government, by a nationalization decree, confiscated all oil lands in Russia, among them the land of plaintiffs, Russian nationals, and sold oil extracted therefrom to defendant. Plaintiffs sought an accounting, claiming that the confiscatory decrees of the unrecognized Soviet government and seizure of oil lands thereunder had no legal effect. A communication from the State Department was introduced: "The Department of State is cognizant of the fact that the Soviet regime is exercising control and power in territory of the former Russian Empire and the Department of State has no disposition to ignore that fact. The refusal of the government of the United States to accord recognition to the Soviet regime is not based on the grounds that that regime does not exercise control and authority in territory of the former Russian Empire, but for other reasons." Held, plaintiff could not recover. M. Salimoff & Co. v. Standard Oil Co. of New York, 262 N. Y. 220, 186 N. E. 679 (1933).
INTERNATIONAL LAW - VALIDITY OF SOVIET DECREES,
Mich. L. Rev.
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