At first blush, the recent judgment of the U.S. Supreme Court in Zivotofsky v Kerry (Zivotofsky II) reads as a strikingly American affair concerning the enduring force of the separation of powers under a written Constitution. Finding that the President has the exclusive power to recognize foreign states and their territory, the Court holds that a statute of Congress encroaches upon this power and declares it unconstitutional. The reasoning of both the Court and the minority justices is largely a narrative of U.S. Constitutional history. So one might ask: does this decision really have anything to say of significance outside the U.S. context about the scope of the executive function in foreign relations?