[1][2] On January 15, 1916, the British steamship SS Appam was captured off the Canary Islands by the German auxiliary cruiser SMS Möwe.

The German government appealed to the Supreme Court of the United States, which on March 6, 1917 handed down a decision that a belligerent nation may not bring prizes of war into a neutral port.

The decision, written by Justice William R. Day, affirmed decrees by Federal Judge Waddill, and upheld the original ruling by Secretary of State Robert Lansing that prizes coming into American ports unaccompanied by captor warships have the right to remain only long enough to make themselves seaworthy.

The court stated that neither the Treaty of 1799 with Prussia, the Hague conventions nor the Declaration of London, entitled any belligerents to make American ports a place of deposit of prizes as spoils of war under such circumstances.

From the beginning of its history this country has been careful to maintain a neutral position between warring governments, and not to allow use of its ports in violation of the obligations of neutrality, nor to permit such use beyond the necessities arising from perils of the seas or the necessities of such vessels as to seaworthiness, provisions and supplies.After return to its initial owners, the ship was renamed SS Mandingo for the rest of the war before reverting to her original name in 1919.