When the Supreme Court held that the executive branch has exclusive authority to recognize foreign sovereigns in the Jerusalem passport case, Zivotofsky v. Kerry (Zivotofsky II), Jack Goldsmith hailed the decision as a “vindication” of presidential signing statements and executive power. Indeed, in the context of the debate over the treatment of the terror suspects, the New York Times had called such signing statements the “constitutionally ludicrous” work of an overreaching, “imperial presidency.”