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222 United States Sovereign Debt: A Thought Experiment On Default And Restructuringabsolute immunity, it would appear that by virtue of the absence ofany statutory waiver of immunity from execution and any case lawrelating to U.S. domestic assets, no relaxation of absolute immunityhas occurred.Glidden v. Zdanok 148 reflects the conventional wisdom that absoluteimmunity from execution for the recovery of money judgments appliesunder U. S. law. In Glidden, the issue presented was whetherjudges of the Court of Claims (now, Court of Federal Claims) wereArticle III constitutional judges. 149 The Court held that they wereArticle III judges. Writing for the plurality, Justice Harlan acceptedthe proposition that the Court of Claims lacked the power to enforcemoney judgments against the U.S.The problem was recognized in the Congress that created theCourt of Claims, where it was pointed out that if ability to enforcejudgments were made a criterion of judicial power, no tribunalcreated under Article III would be able to assume jurisdictionof money claims against the United States. Cong. Globe,33d Cong., 2d Sess. 113 (1854) (remarks of Senator Stuart). Thesubsequent vesting of such jurisdiction in the District Courts . . .of course bears witness that at least the Congress has not thoughtsuch a criterion imperative. 150The issue here is not precisely one of immunity from execution, butrather one of the exclusive power of Congress over appropriations. 151http://www.sec.gov/Archives/edgar/data/19957/000119312504009460/d424b5.htm (last visited Apr. 10, 2012) (“Chile will not waive immunity from attachmentprior to judgment and attachment in aid of execution under Chilean law with respectto property of Chile located in Chile and with respect to its movable andimmovable property which is destined to diplomatic and consular missions and tothe residence of the head of such missions or to military purposes . . . since suchwaiver is not permitted under the laws of Chile.”). See also Philip R. Wood, ProjectFinance, Subordinated Debt and State Loans 154 (1995) (“A state can pass legislation,binding on its courts, immunising domestic assets from execution, and manyhave done so.”).148 370 U.S. 530 (1962).149 The status of judges of the Court of Customs and Patent Appeals also was atissue.150 Glidden, 370 U.S. at 570.151 U.S. Const. art. I, § 9, cl. 7 (“No Money shall be drawn from the Treasury,but in Consequence of Appropriations made by Law . . .”). Recall the “permanent,