During the nineteenth century, the act lay dormant, partly because American foreign policy receded in importance as an issue. During the twentieth century, however, with the Supreme Court paying greater attention to cases involving the First and Fifth amendments to the Constitution, and with the possibility of American foreign policy being more influenced by private individuals becoming more of a prominent issue in politics, there have been more cases potentially involving the Logan Act. Still, the Logan Act has been rarely enforced, possibly because prosecutors have been concerned that speech between a private citizen and a foreign government may still qualify as free speech and be protected in that regard.