By: Timothy Son ‘27
Volume X – Issue I – Fall 2024
I. INTRODUCTION
What is a “treaty?” When is a treaty enforceable in the U.S. domestic courts? How should the treaties be interpreted? As much as the international law itself, the U.S. jurisprudence on international treaties has been ambiguous, if not, narrowly defined. The U.S. Constitution lays the actors responsible, including the judiciary authority over the treaties, however, it leaves a significant ambiguity in the enforcement of treaties in the U.S. domestic courts. Article II of the U.S. Constitution grants the President the treaty-making power with the consent and advice requirement from the Senate. [1] Article VI, known as the Supremacy Clause, states that all treaties “shall be the supreme Law of the Land; and the Judges in every State shall be bound thereby, any Thing in the Constitution or Laws of any State to the Contrary notwithstanding.” [2] Finally, Article III, Section 2, Clause 1 provides that the judicial power will “extend to all Cases, in Law and Equity, arising under this Constitution, the Laws of the United States, and Treaties made, or which shall be made, under their Authority.” [3] This paper will argue that the Supreme Court’s role in international treaties—specifically in constitutionality, interpretation, and private enforcement of treaties—has been rarely standardized. Recent court cases flipped decades-long precedents on the basic assumptions of treaty interpretation and made abrupt changes in the authority of the President to make treaties, the Congress, and private enforcement.