For the United States, Article One, Section Eight of the Constitution says "Congress shall have power to ... declare War". However, that passage provides no specific format for what form legislation must have in order to be considered a "Declaration of War" nor does the Constitution itself use this term. Many have postulated "Declaration(s) of War" must contain that phrase as or within the title. Others oppose that reasoning. In the courts, the United States First Circuit Court of Appeals in Doe v. Bush said: "[T]he text of the October Resolution itself spells out justifications for a war and frames itself as an 'authorization' of such a war." in effect saying an authorization suffices for declaration and what some may view as a formal Congressional "Declaration of War" was not required by