In Reid v. Covert (1957), while reaffirming the President`s ability to enter into executive agreements, he decided that such agreements could not be contrary to federal law or the Constitution in force. The challenge of obtaining a two-thirds majority on treaties was one of the driving forces behind the enormous proliferation of executive agreements after World War II. Thus, in 1952, the United States signed 14 treaties and 291 executive agreements. These were more executive agreements than those concluded throughout the century, from 1789 to 1889. Executive agreements continue to grow rapidly. Second, international agreements that enter into force with respect to the United States on a different constitutional basis than that of the Council and Senate approval are “non-treaty international agreements” and are often referred to as “executive agreements.” There are different types of executive agreements….