Medellin v. Texas (2008)
Facts: In a Texas trial court, Jose Medellin was convicted for participating in a gang rape and double murder. He was a citizen of Mexico. He was sentenced to death. After his conviction and sentencing, he was informed of his right to contact the Mexican consulate in Texas. On appeal, he argued that he should have been informed of that right during the trial. The United States is a party to an international treaty called the Vienna Convention. A protocol (supplement) to the treaty gives foreign nationals a right to contact their home country's consulate. Medellin argued to the Texas Court of Criminal Appeals that he had an individual right based on a prior Supreme Court case (Sanchez-Llamas v. Oregon). He also argued that the Texas court must abide by a ruling of the International Court of Justice (ICJ), which had held that Medellin's rights under the Vienna Convention (and those of 50 other Mexican nationals in the United States) had been violated. He additionally cited a memorandum from President George W. Bush that had instructed state courts to comply with the ICJ's rulings. The Criminal Appeals court, however, ruled that (1) the Sanchez-Llamas case actually held that ICJ rulings are not binding on state courts; (2) Medellin should have raised the Vienna Convention issue during his trial, not after his conviction; and (3) President Bush had no authority to order a state court to enforce an ICJ ruling.
Issues:
(1) Did President Bush act within his constitutional authority to conduct foreign affairs when he determined that states must comply with U.S. treaty obligations?
(2) Does the U.S. Constitution require states to enforce decisions of the ICJ and, therefore, honor U.S. treaty obligations?
Holding: No to both questions. The Supreme Court in a 6-3 vote held the Vienna Convention was not self-executing. A self-executing treaty is one that requires no additional legislation from Congress to allow it to become U.S. law or to allow litigants to claim rights under it. Therefore, state courts did not have to follow the Vienna Convention. The ICJ's opinion does create an "international obligation" on the part of the United States, but that does not mean its rulings are enforceable "such that the judgment of its own force applies in state and federal courts." In other words, Congress needed to have passed a law to make the treaty's protocol self-executing and enforceable in state courts. President Bush, therefore, was unconstitutionally taking on the powers of Congress in attempting to issue the memorandum to the Texas court. Jose Medellin had no right to contact the Mexican consulate.