The Zivotofsky v. Kerry case took place in 2015 and is a relatively new case. To give background on the case, Zivotofsky was born as a U.S. citizen but upon his birth his parents were living in Jerusalem at the time. During this time the U.S. Government had a policy put into place for an extensive amount of time that no one country had sovereignty over the city of Jerusalem. From this case it was brought to the courts attention that this particular policy contradicts and clashes with the Foreign Relations Authorization Act that was put into place in 2003. The Foreign Relations Authorization Act allowed for a citizen to be listed as being from Israel if he/she was born in Jerusalem.

In this case, the action by the branch of government that