uction is directly involved,
as it is here, there is a right of review by direct appeal to this
court."[261]

The Lend-Lease Act

The most extensive delegation of authority ever made by Congress to the
President to enter into executive agreements occurred within the field
of the cognate powers of the two departments, the field of foreign
relations; and took place at a time when war appeared to be in the
offing, and was in fact only a few months away. The legislation referred
to was the Lend-Lease Act of March 11, 1941[262] by which the President
was empowered for something over two years--and subsequently for
additional periods whenever he deemed it in the interest of the national
defense to do so, to authorize "the Secretary of War, the Secretary of
the Navy, or the head of any other department or agency of the
Government," to manufacture in the government arsenals, factories, and
shipyards, or "otherwise procure," to the extent that available funds
made possible, "defense articles"--later amended to include foodstuffs
and industrial products--and "sell, transfer title to, exchange, lease,
lend, or otherwise dispose of," the same to the "government of any
country whose defense the President deems vital to the defense of the
United States," and on any terms that he "deems satisfactory." Under
this authorization the United States entered into Mutual Aid Agreements
whereby the government furnished its allies in the recent war forty
billions of dollars worth of munitions of war and other supplies.

PRESIDENT PLUS CONGRESS VERSUS SENATE

The partnership which has developed within recent decades between the
President and Congress within the field of their cognate powers is also
illustrated by the act of February 9, 1922, creating a commission to
effect agreements respecting debts owed this country by certain other
governments, the resulting agreements to be approved by Congress;[263]
by the circumstances attending the drawing up in 1944 of the United
Nations Relief and Rehabilitation Convention;[264] by the Joint
Resolution of June 19, 1934, by which the President was authorized to
accept membership for the United States in the International Labor
Office.[265] It is altogether apparent in view of developments like
these that the executive agreement power, especially when it is
supported by Congressional legislation, today overlaps the treaty-making
power.

ARBITRATION AGREEMENTS

In 1904-1905 Secretary of State