Zivotofsky: The Difference Between Inherent and Exclusive Presidential Power
If we stipulate that the Foreign Relations Authorization Act of 2002 presented a genuine constitutional conflict between the President and Congress, reasonable minds can differ about the outcome in Zivotofsky v. Kerry (Zivotofsky 1 The Court’s answer t o the specific question presented is actually the least interesting thing about the decision indeed, the majority avers its insignificance so often that a casual reader might be forgiven for wondering why certiorari was granted in the first place.
Mortenson, Julian Davis. "Zivotofsky: The Difference Between Inherent and Exclusive Presidential Power." AJIL Unbound 109, no. 2 (2015): 45-50.