James Russell Soley, Professor U. S. Navy, Confederate Military History, a library of Confederate States Military History: Volume 7.1, The blockade and the cruisers
Clement Anselm Evans, Ed.

The adoption of this rule by the highest courts in the United States raised a loud outcry on the part of those interested in the traffic, and was severely criticised by publicists abroad, especially by those who favored, in general, the continental view of the laws of war. The United States were accused of sacrificing the rights of neutrals, which they had hitherto upheld, to the interests of belligerents, and of disregarding great principles for the sake of a momentary advantage. In truth, however, the principle adopted by the court was not a new one, though a novel application was made of it to meet a novel combination of circumstances. It had formerly been applied to cases where neutrals, engaged in illegal trade between two ports of a belligerent, had endeavored to screen the illegality of the voyage by the interposition of a neutral port, with or without the landing of goods and the employment of a new conveyance. In these cases Lord Stowell held that the continuity of the voyage was not broken, unless the cargo was really imported into the common stock of the neutral country. That the principle had not been applied to blockades was due to the fact that circumstances had never called for it, as the practice of breaking a blockade had never before been carried out on such a scale, with such perfect appliances, and by the use of such ingenious devices. The really difficult question before the court was as to the sufficiency of the evidence in each case. It was to be expected that every artifice in the nature of simulated papers, pretended ownership, false destination, and fictitious transfers would be adopted to escape liability; and it was the business of the court to penetrate all these disguises, and to ascertain the real character