# Medellín v. Texas **Status: stub — expand.** Supreme Court decision of **March 25, 2008** (552 U.S. 491, 6–3, Roberts) holding that a ruling of the [[International Court of Justice]] — the *Avena* judgment, which found that the United States had violated the Vienna Convention on Consular Relations by failing to notify fifty-one Mexican nationals on death row of their consular rights — was **not automatically enforceable federal law** in American courts, and that President Bush could not make it so by memorandum. The holding that matters structurally: a treaty is domestic law only if it is **self-executing**. A non-self-executing treaty binds the United States internationally but creates no judicially enforceable rights until Congress passes implementing legislation. Since the Senate now routinely attaches a **non-self-executing declaration** to the resolution of ratification, the practical effect is that most modern American treaty commitments have no direct force in court — and the House of Representatives, which has no role in ratification, becomes indispensable at the implementation stage. ## See also - [[How a Treaty Is Made and Ratified]] - [[Supremacy Clause]] - [[International Court of Justice]] - [[Missouri v. Holland]]