W.S. Kirkpatrick and Co. v. Environmental Tectonics Corp., International 493 U.S. 400 (1990) Kirkpatrick and ETC were both trying to win a construction contract in Nigeria. ETC won. ETC won by bribing Nigerian officials. Bribery is technically illegal in Nigeria. Kirkpatrick sued ETC in US Federal Court for damages. ETC claimed that since the contract was an official act of the country of Nigeria, suits in US Courts were barred by the Act of State Doctrine. The Trial Court dismissed the case. Kirkpatrick appealed. The Trial Court found that the suit was barred by the Act of State Doctrine. The Court found that a judicial inquiry into the motivation of a sovereign act might result in embarrassment to the sovereign, or constitute interference with the conduct of US foreign policy. The Court found that allowing Kirkpatrick to make a bribery claim would require a finding that foreign officials were criminals, and that might embarrass the Executive Branch in its conduct of foreign relations. The Appellate Court reversed. ETC appealed. The US Supreme Court affirmed and allowed the case to proceed. The US Supreme Court found that the Act of State Doctrine did not apply because nothing in the suit required a court to declare invalid the official act of a foreign sovereign. "The Act of State Doctrine does not establish an exception for cases and controversies that may embarrass foreign governments, but merely requires that, in the process of deciding, the acts of foreign sovereigns taken within their own jurisdiction shall deemed valid."