Justice Jackson\u2019s Youngstown categories cemented an expansive view of the Executive\u2019s foreign affairs powers, beyond the scope that the Founder\u2019s intended, into Supreme Court jurisprudence. Justice Jackson, in crafting his categories of presidential power, assumed that the Executive has a broad grant of foreign affairs authority because he assumed the Article II phrase \u201cthe executive power\u201d implied some substantive powers beyond the power to execute the law. Justice Jackson\u2019s mistaken thesis when framing the Youngstown categories led to the Court\u2019s holding in Zivotofsky II \u2013 the first time that the Court used the \u201clowest ebb\u201d category to override an act of Congress. Considering Zivotofsky, this Note calls for the Youngstown decision to be narrowed to conform to the original meaning of the Article II phrase \u201cthe executive power\u201d as argued by Professor Julian Mortenson. Mortenson rightly concludes that by only vesting the executive power, the Founders expressly limited the Executive\u2019s authority to the powers enumerated in Article II and did not grant him \u2018residual\u2019 foreign affairs powers. Furthermore, by applying a Montesquieuian framework, it is evident that the Founders not only did not grant residual foreign affairs powers to the Executive but also would have considered any grants or use of residual foreign affairs powers by the Executive as unconstitutional.<\/p>\n