Adopting a functional approach, the article compares European ‘constitutional disobedience’ doctrines and the Calvo doctrine. This latter, elaborated to counteract interventions of foreign powers and positivized in several Latin-American constitutions, has been re-discovered as a counter-hegemonic instrument against sources of international economic law based on neo-liberal ideology. Positive law and judicial practice show that, while today both the European and Calvo doctrines protect the axiological identity of domestic orders against ‘outer’ legal systems influenced by utilitarian rationalities, their implementation and efficacy largely diverge, due to their different socio-legal contexts. The article finally outlines the elements of a “general” constitutional disobedience doctrine, which could be an immanent principle of constitutional orders.