Term: 2007
Docket: 06-984
Jose Ernesto Medellin v. Texas
- Pro
06-984 MEDELLIN V. TEXAS DECISION BELOW: 2006 WL 3302639 CERT. GRANTED 4/30/2007 QUESTION PRESENTED: In the Case Concerning Avena and Other Mexican Nationals (Mex. v. U.S.), I.C.J. No. 128 (judgment of Mar. 31, 2004), the International Court of Justice determined that 51 named Mexican nationals, including petitioner, were entitled to receive review and reconsideration of their convictions and sentences through the judicial process in the United States. On February 28, 2005, President George W. Bush determined that the United States would comply with its international obligation to give effect to the judgment by giving those 51 individuals review and reconsideration in the state courts. However, the Texas Court of Criminal Appeals held that the President’s determination exceeded his powers, and it refused to give effect to the Avena judgment or the President’s determination. This case presents the following questions: 1. Did the President of the United States act within his constitutional and statutory foreign affairs authority when he determined that the states must comply with the United States’ treaty obligation to give effect to the Avena judgment in the cases of the 51 Mexican nationals named in the judgment? 2. Are state courts bound by the Constitution to honor the undisputed international obligation of the United States, under treaties duly ratified by the President with the advice and consent of the Senate, to give effect to the Avena judgment in the cases that the judgment addressed? LOWER COURT CASE NUMBER: AP-75207
In the case of Jose Ernesto Medellin v. Texas, 2007, the U.S. Supreme Court ruled that international treaties are not binding domestic law unless Congress has enacted statutes implementing them or if the treaties are self-executing. The case involved a Mexican national named Jose Ernesto Medellin who was convicted and sentenced to death in Texas for participating in gang rape and murder. He claimed his rights under Vienna Convention on Consular Relations were violated as he was not informed about his right to contact the Mexican consulate after arrest. The International Court of Justice (ICJ) had previously ruled that U.S should review convictions of certain Mexican nationals including Medellin's due to violation of these rights but did not specify remedy measures. The US Supreme Court held that decisions made by ICJ have no automatic effect within US courts and President George W Bush overstepped his powers when he ordered state courts to comply with ICJ ruling without Congressional approval. This decision emphasized separation of powers principle within federal government while also highlighting limitations on how far international law can influence domestic legal proceedings.
In the dissenting opinion for Medellin v. Texas, Justice Breyer, joined by Justices Souter and Ginsburg, argued that the majority's decision undermined America's commitment to international law and its reputation in the global community. They contended that President Bush had constitutional authority to enforce a judgment of the International Court of Justice (ICJ) requiring state courts to review convictions of foreign nationals who were not informed about their right under an international treaty (Vienna Convention on Consular Relations) to consult with their home country’s consulate upon arrest. The dissenters believed this case was unique because it involved both executive power over foreign affairs and Congress' implicit approval through ratification of relevant treaties. They also pointed out that failure to comply with ICJ judgments could harm American citizens abroad if other countries decided likewise not respect these rulings concerning consular rights.
