The initial dismissal of the case on the political question doctrine was an extension of the precedent in "Baker v. Carr". According to Prof. Gwynne Skinner, "most of the claims arising out of the Holocaust have been dismissed based on this doctrine either because decisions were already made regarding reparations, or because the Allied forces had already made decisions about who would be prosecuted for the various crimes committed during the Holocaust". According to Prof. Hannibal Travis: "Initially, U.S. courts dismissed claims by Holocaust survivors on the grounds that international law only gave rise to claims between states and was not self-executing in the absence of implementing legislation in Congress. This erroneous interpretation of §1350 was corrected within a few years, and since 1980, the U.S. federal courts have exercised universal jurisdiction in a nearly unbroken line of cases involving offenses properly alleged to have been committed elsewhere in violation of international law."