In Wong v. Tenneco, Inc. (1985) 39 Cal.3d 126, the plaintiff was a California resident who knowingly created an illegal farming operation in Mexico where legal title to both the operation and the land was in the name of Mexican citizens. ( Id. at pp. 128-133.) Wong brought a breach of contract action against several entities that had participated in the illegal scheme. ( Id. at pp. 132-133.) The Supreme Court held the contract was unenforceable under the comity doctrine, explaining that "the trial court properly declined to involve our courts in this flagrant effort to circumvent Mexican law." ( Id. at pp. 133-134.)