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Source: http://washingtonbureau.typepad.com/law/2009/07/jerusalem-in-court.html
When Will the U.S. Officially Recognize Jerusalem as Part of Israel?
[McClatchy] Michael Doyle - In October 2002, Menachem Zivotofsky was born in Jerusalem to U.S. citizens. In December 2002, Menachem's mother applied for a U.S. passport and a Consular Report of Birth for her son at the U.S. Embassy, requesting that both documents record her son's place of birth as "Jerusalem, Israel." Congress in the 2002 foreign aid authorization bill included language stating that "for purposes of the registration of birth...or issuance of a passport of a United States citizen born in the city of Jerusalem, the Secretary [of State] shall, upon the request of the citizen or the citizen's legal guardian, record the place of birth as Israel." But President Bush signed a statement declaring the language non-binding. So the family sued. Last Friday the Circuit Court of Appeals for the District of Columbia determined that the president has "exclusive and unreviewable constitutional power to keep the United States out of the debate over the status of Jerusalem."