1 In Etlimar S. A. of Casablanca v. U. S., 106 F. Supp. 191 (Ct. Cls., July 15, 1952), the Byrnes-Blum agreement of May 28, 1946, between the U. S. and France on Lend-Lease Settlement, etc. (T.I.A.S., No. 1928), was held to provide through local settlement in Morocco the sole remedy for a company whose property was requisitioned by American forces in Morocco in 1942, the Court of Claims being unable to hear a claim for additional compensation.

In Cross v. Pace, 106 F. Supp. 484 (Dist. Col., July 1, 1952), dismissing complaint against the Secretary of the Army and other officials which sought an injunction against maintenance of a dam in the St. Lawrence River resulting in high water levels of Lake Ontario, the court rejected plaintiffs’ contention that the Act of Congress authorizing joint construction of the dam with Canada was “in reality a treaty” and “therefore unconstitutional as a usurpation of the President’s treaty-making power.” The court considered the power of Congress over navigable waterways a sufficient basis for the 1902 Act, pointing to the cases which had sustained international agreements under authority of Congress, and adding that the relief sought could not be obtained against the Executive Branch of the Government.