I believe that the United States claimed the island called Navassa in 1857 under the Guano Islands Act. The government of Haiti has always disputed this claim. Navassa is currently administered by the US Fish and Wildlife Service.

In 1889 black workers brought to mine guano on Navassa rebelled against their conditions. After the rebellion was suppressed, one Henry Jones was brought to Baltimore, and tried and convicted of murder for killing an overseer during that rebellion. His appeal went to the Supreme Court, which affirmed the jurisdiction and application of US laws, despite Haiti's claims: "Who is the sovereign, de jure or de facto, of a territory, is not a judicial, but a political, question, the determination of which by the legislative and executive departments of any government conclusively binds the judges, as well as all other officers, citizens, and subjects of that government." Jones v. US, 137 US 202 (1890).

This seems to mean that in the eyes of the US Supreme Court, where sovereignty is at issue, might makes right.

Ben Chitty

Yonkers, NY