Opinion · Supreme Court of the United States

Medellin v. Texas

552 U.S. 491

Type
Opinion
Court
Supreme Court of the United States
Jurisdiction
Federal
Date
2008-03-25
Topic
general

How later courts describe this case

  • holding that a later-in-time self-executing treaty supersedes a federal statute and that a later-in-time federal statute supersedes a treaty
  • holding that the “interpretation of a treaty, like the interpretation of a statute, begins with its text”
  • recognizing that non self-executing treaties — “while they constitute international law commitments — do not by themselves function as binding federal law.”
  • holding that the President has the “lead role” in making “sensitive foreign policy decisions”
  • concluding that absent self-executing status or implementing statutes, such treaties’ commitments are “not domestic law”
  • holding that President George W. Bush’s memorandum in response to an international court’s decision was “not a rule of domestic law binding in state and federal courts”
  • saying that " ‘[p]ast practice does not, by itself, create power’ ” in the context of executive action by the President
  • reaffirming that non-self-executing ratifications of international treaties cannot act as a limit on state power unless legislation exists implementing the treaty

Citator

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Cited by
541 opinions

Headnotes

  1. International Law — Treaties A treaty may constitute an international commitment without being binding domestic law; it has domestic effect only if Congress has enacted implementing statutes or the treaty itself conveys an intention to be self-executing and is ratified on that basis. *Foster v. Neilson*, 2 Pet. 253, 314
  2. International Law — Treaties Treaty interpretation, like statutory interpretation, begins with the treaty's text; because a treaty is an agreement among sovereign powers, the negotiation and drafting history and the postratification understanding of signatory nations are proper aids to interpretation. *Air France v. Saks*, 470 U.S. 392, 396–397; *Zicherman v. Korean Air Lines Co.*, 516 U.S. 217, 226
  3. International Law — Treaties A treaty is self-executing, and equivalent to an act of the legislature, when it operates of itself without the aid of any legislative provision; when its stipulations are not self-executing, they can be enforced only pursuant to legislation carrying them into effect. *Foster*, 2 Pet., at 314–315; *Whitney v. Robertson*, 124 U.S. 190, 194
  4. International Law — Treaties A non-self-executing treaty addresses itself to the political, not the judicial, department; the legislature must execute the contract before it can become a rule for the Court, and until implementing legislation is passed the courts are not at liberty to disregard the existing laws on the subject. *Foster*, 2 Pet., at 314–315
  5. International Law — Treaties A treaty is primarily a compact between independent nations that ordinarily depends for enforcement of its provisions on the interest and honor of the governments party to it; if those fail, the infraction becomes the subject of international negotiations and reclamations, and the judicial courts can give no redress. *Head Money Cases*, 112 U.S. 580, 598
  6. International Law — Self-Execution Determined by Treaty Language Whether a treaty is self-executing turns on the treaty's language as reflecting the intent of the President who negotiated it and the Senate that ratified it, not on a judgment-by-judgment or multifactor analysis; a treaty need not expressly provide for self-execution, but the text must indicate that the parties intended the agreement to have domestic effect. *Foster*, 2 Pet., at 314–315; *Percheman*, 7 Pet., at 87, 89
  7. International Law — Treaties Not all international law obligations automatically constitute binding federal law enforceable in United States courts; the question whether a particular international obligation has automatic domestic legal effect such that it applies of its own force in state and federal courts is a matter for the courts to decide. *Sanchez-Llamas v. Oregon*, 548 U.S. 331, 353–354
  8. International Law — Optional Protocol to the Vienna Convention The Optional Protocol to the Vienna Convention is most naturally read as a bare grant of jurisdiction: it says nothing about the effect of an ICJ decision, does not commit signatories to comply with such a decision, and is silent as to any enforcement mechanism.
  9. International Law — U.N. Charter Article 94(1) The obligation to comply with ICJ judgments derives from Article 94(1) of the U.N. Charter, under which each Member "undertakes to comply with the decision of the International Court of Justice in any case to which it is a party." U.N. Charter, Art. 94(1), 59 Stat. 1051
  10. International Law — Interpretation of "Undertakes to Comply" The phrase "undertakes to comply" in Article 94(1) is a commitment by member states to take future action through their political branches; it does not provide that the United States "shall" or "must" comply and does not indicate that the Senate, in ratifying the Optional Protocol, intended to vest ICJ decisions with immediate legal effect in domestic courts. U.N. Charter, Art. 94(1); *Committee of United States Citizens Living in Nicaragua v. Reagan*, 859 F.2d 929, 938
  11. International Law — Enforcement of ICJ Judgments Article 94(2) of the U.N. Charter provides the sole remedy for noncompliance with an ICJ judgment—referral to the U.N. Security Council by an aggrieved state—and the Security Council's action is not absolute: a resolution is required, and the United States retains an unqualified right to veto any such resolution. U.N. Charter, Art. 94(2), 59 Stat. 1051
  12. International Law — ICJ Judgments as Domestic Law Construing ICJ judgments as automatically enforceable domestic law would eliminate the option of noncompliance contemplated by Article 94(2) and would transfer sensitive foreign policy decisions to state and federal courts, which would not be empowered to decide whether to comply with a judgment.
  13. International Law — The Avena Judgment as Binding Domestic Law The *Avena* judgment creates an international law obligation on the part of the United States but is not automatically binding domestic law, because none of the relevant treaty sources—the Optional Protocol, the U.N. Charter, or the ICJ Statute—creates binding federal law in the absence of implementing legislation, and no such legislation has been enacted.
  14. International Law — Jurisdiction and Consent Distinguished Submitting to jurisdiction and agreeing to be bound are distinct; a party may agree to compulsory nonbinding arbitration, requiring it to appear before the tribunal without obligating it to treat the tribunal's decision as binding. NAFTA, Art. 2018(1)
  15. International Law — Parties Before the ICJ Only states may be parties in cases before the ICJ, and an ICJ decision has no binding force except between the parties and in respect of that particular case. ICJ Statute, Arts. 34(1), 59, 59 Stat. 1059, 1062
  16. International Law — Diplomatic Protection The fact that an ICJ case is precipitated by a dispute involving particular persons or entities, which a nation elects to take up as its own in the exercise of diplomatic protection, does not make those persons or entities parties to the ICJ proceeding. *Case Concerning the Barcelona Traction, Light & Power Co. (Belg. v. Spain)*, 1970 I.C.J. 3
  17. International Law — Deference to Executive Interpretation The United States' interpretation of a treaty is entitled to great weight, and the Executive Branch has consistently adhered to the view that the relevant treaties do not create domestically enforceable federal law. *Sumitomo Shoji America, Inc. v. Avagliano*, 457 U.S. 176, 184–185
  18. International Law — Postratification Understanding The postratification understanding of signatory nations is relevant to whether a treaty provision is binding federal law; that no nation party to the Optional Protocol or the Vienna Convention treats ICJ judgments as binding in domestic courts strongly suggests the treaty should not be so viewed in U.S. courts. *Zicherman*, 516 U.S., at 226; *Sanchez-Llamas*, 548 U.S., at 343–344
  19. International Law — Treaty Implementation and State Procedure Absent a clear and express statement to the contrary, the procedural rules of the forum state govern implementation of a treaty in that state, and where a treaty does not provide a particular remedy either expressly or implicitly, it is not for the federal courts to impose one on the states. *Sanchez-Llamas*, 548 U.S., at 347, 351; *Breard v. Greene*, 523 U.S. 371, 375
  20. International Law — Judgments of International Tribunals An agreement to abide by the result of an international adjudication can be a treaty obligation like any other, so long as it is consistent with the Constitution; a holding that a particular ICJ judgment is not automatically enforceable as domestic law does not render the underlying treaty useless, because such judgments remain international obligations subject to political and diplomatic negotiation. *Head Money Cases*, 112 U.S., at 598
  21. International Law — Treaties Congress may give international tribunal judgments domestic effect through implementing legislation and knows how to do so when it desires that result; the responsibility for transforming an international obligation arising from a non-self-executing treaty into domestic law falls to Congress, not the Executive. *Foster*, 2 Pet., at 315; Foreign Affairs Reform and Restructuring Act of 1998, Pub. L. 105-277, § 2242
  22. International Law — Foreign Judgments The rule that a judgment will be recognized and enforced despite an error of fact or law applies to foreign judgments, but judgments of foreign courts awarding injunctive relief—especially against sovereign states—are not generally entitled to enforcement. 1 Restatement (Second) of Conflict of Laws § 106; 2 Restatement (Third) of Foreign Relations § 481, Comment b
  23. Constitutional Law — Separation of Powers The President's authority to act must stem either from an act of Congress or from the Constitution itself; the power to make necessary laws is in Congress and the power to execute is in the President, and the Take Care Clause does not permit the President to make law. *Youngstown Sheet & Tube Co. v. Sawyer*, 343 U.S. 579, 585, 587; *Hamdan v. Rumsfeld*, 548 U.S. 557, 591
  24. Constitutional Law — Presidential Authority Under Youngstown Presidential authority is at its maximum when the President acts pursuant to an express or implied authorization of Congress; in the absence of either a congressional grant or denial of authority he may rely only on his own independent powers, though a zone of twilight may exist in which he and Congress have concurrent authority or its distribution is uncertain; and when he takes measures incompatible with the expressed or implied will of Congress his power is at its lowest ebb, and his actions can be sustained only by disabling Congress from acting upon the subject. *Youngstown*, 343 U.S., at 635, 637–638 (Jackson, J., concurring)
  25. Constitutional Law — Congressional Acquiescence Congressional acquiescence is pertinent when the President's action falls within the second *Youngstown* category—when he acts in the absence of either a congressional grant or denial of authority—and not the third; a systematic, unbroken executive practice long pursued to the knowledge of Congress and never before questioned may raise a presumption of congressional consent, but past practice does not by itself create power. *Dames & Moore v. Regan*, 453 U.S. 654, 668
  26. Constitutional Law — President's Foreign Affairs Authority The Constitution places with the President the vast share of responsibility for the conduct of the nation's foreign relations and commits the conduct of foreign relations to the political departments, so that the President has an array of political and diplomatic means available to enforce international obligations; but unilaterally converting a non-self-executing treaty into a self-executing one is not among them. *American Ins. Assn. v. Garamendi*, 539 U.S. 396, 414; *Oetjen v. Central Leather Co.*, 246 U.S. 297, 302
  27. Constitutional Law — Non-Self-Executing Treaties A non-self-executing treaty, by definition, is one ratified with the understanding that it will not have domestic effect of its own force; its non-self-executing character implicitly prohibits the President from unilaterally making its obligations binding on domestic courts and precludes any implicit congressional authorization for the President, acting alone, to achieve the same domestic result. *Foster*, 2 Pet., at 314–315
  28. Constitutional Law — Treaty Implementation and the Political Branches Each constitutional means of giving domestic effect to an international treaty obligation requires joint action by the Executive and Legislative Branches: the Senate may ratify a self-executing treaty made by the Executive, or, if the ratified treaty is not self-executing, Congress may enact implementing legislation approved by the President. U.S. Const., Arts. I, §§ 1, 7; II, § 2
  29. Constitutional Law — Compare and Contrast — Executive Settlement of Claims The claims-settlement cases, which uphold executive agreements to settle civil claims between American citizens and foreign governments or entities, involve a narrow set of circumstances and do not establish authority for a presidential directive to state courts to reopen final criminal judgments and set aside neutrally applicable state law. *American Ins. Assn. v. Garamendi*, 539 U.S. 396, 415
  30. International Law — ICJ Judgment and Congressional Acquiescence The President's memorandum does not independently require the states to provide review and reconsideration of the claims of the 51 Mexican nationals named in *Avena* without regard to state procedural default rules; his asserted authority falls within the third *Youngstown* category, and neither Congress's failure to act following the resolution of prior ICJ controversies nor its authorization of the President to represent the United States before the United Nations and the ICJ demonstrates acquiescence in a unilateral power to displace state law. 22 U.S.C. § 287; *Youngstown*, 343 U.S., at 637–638
  31. International Law — Limitation on Presidential Implementation The combination of a non-self-executing treaty and the lack of implementing legislation does not preclude the President from acting to comply with an international treaty obligation by other means consistent with the Constitution, but he may not rely upon a non-self-executing treaty to establish binding rules of decision that preempt contrary state law. *Foster*, 2 Pet., at 315; *Whitney*, 124 U.S., at 194
  32. International Law — Treaties Under the *Sanchez-Llamas* approach, nothing in the ICJ's structure or purpose suggests its interpretations were intended to be conclusive on U.S. courts, and the Court's prior cases holding some treaties self-executing establish only that some international agreements are self-executing and others are not. *Sanchez-Llamas*, 548 U.S., at 354
  33. Criminal Law & Procedure — Successive Habeas Petitions Neither an ICJ judgment nor a presidential memorandum constitutes binding federal law that preempts state limitations on the filing of successive habeas petitions, and a state court may dismiss a successive habeas application as an abuse of the writ where the petitioner failed to raise his Vienna Convention claim in a timely manner under state law. *Ex parte Medellín*, 223 S.W.3d 315, 352 (Tex. Crim. App. 2006); *Breard*, 523 U.S., at 375