The International Court of Justice's Avena judgment and the President's Memorandum to follow the ICJ's ruling do not constitute enforceable federal law that pre-empts state limitations on the filing of successive habeas petitions. A treaty is not binding domestic law unless Congress has enacted statutes implementing it or the treaty is self-executing once ratified. The ICJ statute is not self-executing, and no legislation implementing it has been enacted. Because Congress has not enacted legislation to bind domestic courts by the treaty, the President is implicitly prohibited from unilaterally making treaty obligations binding on domestic courts. Medellin v. Texas, 06–984 [1].