Note 395 — Chapter IV · WARFARE ON SEA

See Hall, § 151, p. 479:—"The English Courts refuse to accept such arrangements (for ransom) from the effect of the rule that the character of an alien enemy carries with it a disability to sue, and compel payment of the debt indirectly through an action brought by the imprisoned hostage for the recovery of his freedom." The American Courts, in contradistinction to the British, recognise ransom bills. See on the one hand, the case of Cornu v. Blackburne (1781), 2 Douglas, 640, Anthon v. Fisher (1782), 2 Douglas, 649 note, the Hoop, 1 C. Rob. 201; and, on the other, Goodrich and De Forest v. Gordon (1818), 15 Johnson, 6.