On June 8, 2015, the U.S. Supreme Court (the Court) held [3] in Zivotofsky v. Kerry that an Act of Congress [4] that would allow U.S. citizens born in Jerusalem to have their place of birth listed on their passports as “Israel” infringes on the President’s exclusive power to grant formal recognition to foreign states.  The Court notes that the law “forces the President, through the Secretary of State, to identify, upon request, citizens born in Jerusalem as being born in Israel when, as a matter of United States policy, neither Israel nor any other country is acknowledged as having sovereignty over Jerusalem.”  The Court held that “[t]he President has the exclusive power to grant formal recognition to a foreign sovereign” and “[b]ecause the power to recognize foreign states resides in the President alone, [the law] infringes on the Executive’s consistent decision to withhold recognition with respect to Jerusalem.”