From Muddled to Medellín: A Legal History of Sole Executive Agreements

The legal history of sole executive agreements is muddled at best. Over the years the Supreme Court has created a confused doctrine concerning sole executive agreements through its Belmont, Pink, Dames & Moore, and Garamendi decisions by making overly broad generalizations about the preemptive weight of these agreements. This Note argues that the analysis in the recent Medellín v. Texas decision helps to clarify the confusion over sole executive agreements by establishing limits on their preemptive weight.