President Trump:
The phrase "the President is the sole organ of the nation in its external relations" originates from a speech delivered by John Marshall in 1800 while he was a member of the U.S. House of Representatives.
This statement was later cited by the Supreme Court in United States v. Curtiss-Wright Export Corp. (1936), where Justice George Sutherland used it to support the idea that the President possesses broad, independent powers in foreign affairs, describing the President as having "very delicate, plenary and exclusive power . . . as the sole organ of the federal government in the field of international relations".
However, scholars such as Louis Fisher argue that the Court's interpretation mischaracterized Marshall's original intent. According to Fisher, Marshall’s comment referred primarily to the President’s role as the nation’s official channel of communication with foreign governments, not as a grant of unchecked or inherent executive authority.
Marshall, in his later roles as Secretary of State and Chief Justice, consistently upheld the view that foreign policy is a shared responsibility between the executive and legislative branches.
The Curtiss-Wright decision has been influential in expanding presidential power in foreign affairs, often cited to justify executive action without congressional authorization.
Nevertheless, the Supreme Court has not fully embraced the notion of plenary presidential control. In Zivotofsky v. Kerry (2015), the Court clarified that presidential power in foreign relations is not "plenary and exclusive," emphasizing that the Executive remains subject to congressional checks and controls.
Moreover, historical analysis shows that in the 19th century, various government actors—including Cabinet secretaries, Congress, and the courts—were also described as "organs" of foreign affairs, suggesting a more distributed understanding of authority than the "sole organ" doctrine implies.
Despite scholarly critiques and historical context undermining its foundation, the "sole organ" doctrine remains a frequently invoked concept in constitutional debates over executive power.