Zivotofsky v. Clinton

E903976

United States Supreme Court case legal case

Zivotofsky v. Clinton is a 2012 U.S. Supreme Court case that limited the scope of the political question doctrine by allowing courts to review a dispute over the recognition of Jerusalem in U.S. passports.

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All labels observed (3)

Label	Occurrences
Zivotofsky v. Kerry	4
Zivotofsky v. Clinton canonical	3
Zivotofsky v. Secretary of State, 571 F.3d 122 (D.C. Cir. 2009)	1

How this entity was disambiguated

This entity first appeared as the object of triple T11085061 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.

NED1 Entity disambiguation (via context triple) gpt-5-mini-2025-08-07

Target entity: Zivotofsky v. Clinton
Context triple: [political question doctrine, leadingCase, Zivotofsky v. Clinton]

A. INS v. Chadha
INS v. Chadha is a landmark 1983 U.S. Supreme Court case that struck down the legislative veto as unconstitutional, significantly reshaping the balance of power between Congress and the executive branch.
B. Chiafalo v. Washington
Chiafalo v. Washington is a 2020 U.S. Supreme Court case that unanimously upheld states’ authority to penalize or replace “faithless electors” who do not vote in line with their state’s popular vote in presidential elections.
C. Cantwell v. Connecticut
Cantwell v. Connecticut is a 1940 U.S. Supreme Court case that first applied the First Amendment’s Free Exercise Clause to the states, striking down a state law that improperly restricted religious proselytizing.
D. Hamdi v. Rumsfeld
Hamdi v. Rumsfeld is a 2004 U.S. Supreme Court case that held American citizens designated as enemy combatants have the right to challenge their detention before a neutral decision-maker.
E. Eisenstadt v. Baird
Eisenstadt v. Baird is a landmark 1972 U.S. Supreme Court decision that extended the right to possess and use contraceptives to unmarried individuals, significantly advancing privacy and equal protection jurisprudence.
F. None of above. chosen
G. Unsure - the case is ambiguous/there is not enough information to decide.

NED2 Entity disambiguation (via description) gpt-5-mini-2025-08-07

Target entity: Zivotofsky v. Clinton
Target entity description: Zivotofsky v. Clinton is a 2012 U.S. Supreme Court case that limited the scope of the political question doctrine by allowing courts to review a dispute over the recognition of Jerusalem in U.S. passports.

A. INS v. Chadha
INS v. Chadha is a landmark 1983 U.S. Supreme Court case that struck down the legislative veto as unconstitutional, significantly reshaping the balance of power between Congress and the executive branch.
B. Chiafalo v. Washington
Chiafalo v. Washington is a 2020 U.S. Supreme Court case that unanimously upheld states’ authority to penalize or replace “faithless electors” who do not vote in line with their state’s popular vote in presidential elections.
C. Cantwell v. Connecticut
Cantwell v. Connecticut is a 1940 U.S. Supreme Court case that first applied the First Amendment’s Free Exercise Clause to the states, striking down a state law that improperly restricted religious proselytizing.
D. Hamdi v. Rumsfeld
Hamdi v. Rumsfeld is a 2004 U.S. Supreme Court case that held American citizens designated as enemy combatants have the right to challenge their detention before a neutral decision-maker.
E. Eisenstadt v. Baird
Eisenstadt v. Baird is a landmark 1972 U.S. Supreme Court decision that extended the right to possess and use contraceptives to unmarried individuals, significantly advancing privacy and equal protection jurisprudence.
F. None of above. chosen

Statements (49)

Predicate	Object
instanceOf	United States Supreme Court case ⓘ legal case ⓘ
citation	132 S. Ct. 1421 ⓘ 182 L. Ed. 2d 423 ⓘ 566 U.S. 189 ⓘ
clarifiedDoctrine	courts may decide cases requiring interpretation of statutes even when they touch on foreign policy recognition issues ⓘ political question doctrine is narrow and limited ⓘ
concernsCountry	Israel ⓘ
concernsGovernmentAction	U.S. recognition policy regarding Jerusalem ⓘ
concernsLocation	Jerusalem ⓘ
concurringInJudgmentBy	Justice Stephen G. Breyer ⓘ linked to: Stephen G. Breyer
court	Supreme Court of the United States ⓘ
dateArgued	2011-11-07 ⓘ
dateDecided	2012-03-26 ⓘ
decisionType	vacated and remanded ⓘ
dissentingBy	Justice Ruth Bader Ginsburg ⓘ linked to: Ruth Bader Ginsburg Justice Stephen G. Breyer ⓘ linked to: Stephen G. Breyer
docketNumber	10-699 ⓘ
governmentPosition	State Department refused to list “Israel” as place of birth for U.S. citizens born in Jerusalem ⓘ
hasParty	Hillary Rodham Clinton ⓘ linked to: Hillary Diane Rodham Menachem Binyamin Zivotofsky ⓘ
hasPartyRole	Hillary Rodham Clinton – respondent ⓘ linked to: Hillary Clinton Menachem Binyamin Zivotofsky – petitioner ⓘ
involvesStatute	Section 214(d) of the Foreign Relations Authorization Act, Fiscal Year 2003 ⓘ
jurisdiction	United States federal courts ⓘ linked to: U.S. federal courts
legalIssue	passport designation of place of birth ⓘ political question doctrine ⓘ recognition power in foreign affairs ⓘ separation of powers ⓘ
lowerCourtHolding	claim presented a nonjusticiable political question ⓘ
majorityJustices	Anthony M. Kennedy ⓘ Antonin Scalia ⓘ Clarence Thomas ⓘ Elena Kagan ⓘ John G. Roberts, Jr. ⓘ linked to: John G. Roberts Jr. Samuel A. Alito, Jr. ⓘ linked to: Samuel A. Alito Jr. Sonia Sotomayor ⓘ
majorityOpinionBy	Chief Justice John G. Roberts, Jr. ⓘ linked to: John G. Roberts Jr.
originatingCourt	United States Court of Appeals for the District of Columbia Circuit ⓘ
originatingCourtDecision	Zivotofsky v. Secretary of State, 571 F.3d 122 (D.C. Cir. 2009) ⓘ linked to: Zivotofsky v. Clinton
overruledLowerCourtOn	application of political question doctrine ⓘ
plaintiffClaim	right to have “Israel” listed as place of birth on U.S. passport ⓘ
subjectMatter	constitutional law ⓘ foreign relations law of the United States ⓘ
subsequentRelatedCase	Zivotofsky v. Kerry ⓘ linked to: Zivotofsky v. Clinton
subsequentRelatedCaseCitation	576 U.S. 1 ⓘ
SupremeCourtHolding	case does not present a political question beyond the competence of the courts ⓘ federal courts have authority to decide the constitutionality of Section 214(d) of the Foreign Relations Authorization Act, Fiscal Year 2003 ⓘ
termOfCourt	October Term 2011 ⓘ

How these facts were elicited