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Constitutional Law Keyed to Shanor
Zivotofsky v. Kerry
Citation:
135 S. Ct. 2076 (2015)Facts
The President had not recognized any country’s sovereignty over Jerusalem, and the State Department’s Foreign Affairs Manual instructed employees to record only “Jerusalem,” not any country, as the place of birth of passports of citizens born in Jerusalem. In 2002, Congress passed the Foreign Relations Authorization Act. Section 214 of the Act allowed citizens born in Jerusalem to list their place of birth as Israel, contradicting the Foreign Affairs Manual instructions. After American Embassy clerks refused Zivotofsky’s mother’s request to list her son’s birthplace as “Jerusalem, Israel” on his passports, Zivotofsky’s parents filed a complaint against the government.
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