Court relied in holding that the Confederation formed by the
seceding States could not be recognized as having any legal
existence.[1544] Today, its practical significance lies in the
limitations which it implies upon the power of the States to deal with
matters having a bearing upon international relations. In the early case
of Holmes _v._ Jennison,[1545] Chief Justice Taney invoked it as a
reason for holding that a State had no power to deliver up a fugitive
from justice to a foreign State. Recently the kindred idea that the
responsibility for the conduct of foreign relations rests exclusively
with the Federal Government prompted the Court to hold that, since the
oil under the three mile marginal belt along the California coast might
well become the subject of international dispute and since the ocean,
including this three mile belt, is of vital consequence to the nation in
its desire to engage in commerce and to live in peace with the world,
the Federal Government has paramount rights in and power over that belt,
including full dominion over the resources of the soil under the water
area.[1546] In Skiriotes _v._ Florida,[1547] the Court, on the other
hand, ruled that this clause did not disable Florida from regulating the
manner in which its own citizens may engage in sponge fishing outside
its territorial waters. Speaking for a unanimous Court, Chief Justice
Hughes declared: "When its action does not conflict with federal
legislation, the sovereign authority of the State over the conduct of
its citizens upon the high seas is analogous to the sovereign authority
of the United States over its citizens in like circumstances."[1548]

BILLS OF CREDIT

Within the sense of the Constitution, bills of credit signify a paper
medium of exchange, intended to circulate between individuals; and
between the Government and individuals, for the ordinary purposes of
society. It is immaterial whether the quality of legal tender is
imparted to such paper. Interest bearing certificates, in denominations
not exceeding ten dollars, which were issued by loan offices established
by the State of Missouri, and made receivable in payment of taxes or
other moneys due to the State, and in payment of the fees and salaries
of State officers, were held to be bills of credit whose issuance was
banned by this section.[1549] The States are not forbidden, however, to
issue coupons receivable for taxes,[1550] nor to execute instruments
binding thems