Oregon claimed a dead woman's estate because her only heirs lived in East Germany, and the Supreme Court ruled in 1968 that a state cannot run its own Cold War through probate

An Oregon resident, Pauline Schrader^†, died without a will in 1962. Her only heirs, including Oswald Zschernig, lived in East Germany. Members of the Oregon State Land Board asked the probate court to escheat the estate's net proceeds to the state. The Oregon statute let a foreign heir take only by proving three things: that Americans had a reciprocal right to inherit in the heir's country, that Americans could receive estate money from there, and that the heir would receive the money "without confiscation." The trial court found reciprocity not proved. The Oregon Supreme Court let the heirs take the real property under a 1923 treaty with Germany but not the personal property. On 15 January 1968 the US Supreme Court reversed. Justice William O. Douglas wrote that the statute intruded into foreign affairs, which the Constitution gives to the President and Congress. He wrote that in such cases "foreign policy attitudes, the freezing or thawing of the 'cold war,' and the like are the real desiderata," and that some state decisions "radiate some of the attitudes of the 'cold war.'" Justice White dissented. A 1970 law review article argued that state courts then applied the ruling too broadly. In 2003 the Supreme Court relied on the case again in American Insurance Association v. Garamendi.