4/5/1982: Justice Abe Fortas dies.

Mostly law professors | Sometimes contrarian | Often libertarian | Always independent | Est. 2002
4/5/1982: Justice Abe Fortas dies.

What’s on your mind?
I oppose Trump's efforts to deny birthright citizenship chiildren of undocumented immigrants. But birthright citizenship is not the ideal policy.

For a variety of reasons, I oppose Donald Trump's efforts to end birthright citizenship for children of undocumented immigrants and those in the US on temporary visas. And I have argued he deserves to lose the Supreme Court case on this issue. But unlike many other opponents of Trump's policy and of his constitutional arguments, I am not convinced birthright citizenship is the ideal system. It is, at most, only a second-best option, in the sense that it's better than the currently likely alternative.
Under current political conditions, that likely alternative is subjecting hundreds of thousands of children to deportation, and many adults, as well. Even though Trump's executive order is limited to children born at least 30 days after it was issued, the logic of his legal arguments would deprive millions of adults and older children of their right to live in the United States, as well. If the Fourteenth Amendment denies birthright citizenship to children of undocumented immigrants and temporary visa-holders, that fact did not begin suddenly in 2025, but must have been true all along. Thus, the likely consequence of a legal victory for Trump would be grave harm to millions of children and descendants of immigrants, plus severe damage to the American economy and society from the resulting deportations and legal uncertainty. In addition, millions of other Americans would find it difficult to prove citizenship status if it can no longer be done on the basis of a birth certificate.
But while birthright citizenship is better than the likely alternative at this point in history, I do not believe it is the ideal policy. I explained some of the reasons why in a 2018 post:
Unlike most other advocates of immigration and immigrant rights, I have significant reservations about birthright citizenship. In my view, important human rights should not be so heavily dependent on parentage and place of birth. Our current citizenship system has all too much in common with medieval hereditary aristocracy, under which freedom of movement and other crucial rights were largely dependent on ancestry. I cannot outline anything like a comprehensive alternative here. But, as a general rule, I would prefer a system under which some rights now largely determined by citizenship (particularly freedom of movement, residency, and employment) were delinked from citizenship and made presumptively available to everyone, and citizenship itself were made easier to acquire through pathways that do not require the applicant to be a relative of a current citizen.
More generally, one of my (and many others') main objections to immigration restrictions is that they restrict people's liberty and opportunity based on arbitrary circumstances of ancestry and place of birth. If you were born to the right parents or in the right place, you get to live and work in the US; if not, you can only do so if the government gives you permission, which in the vast majority of cases is likely to be denied. In that respect, they are very similar to racial segregation and South African apartheid. In both cases, liberty is gravely restricted and many are consigned to a lifetime of poverty and oppression because of morally arbitrary circumstances of birth over which they have no control.
Birthright citizenship is an improvement, in this respect, over a policy based on ancestry and parentage. For many children, it creates an alternative pathway to get around unjust restrictions. But it still restricts liberty and opportunity based on circumstances of birth, in this case based on place of birth, as well as parentage. And people have no more control over the location of their birth than over the identity of their parents. Neither determines your moral worth or how much liberty you are entitled to.
Thus, the far superior policy is simply to let people live and work where they want, regardless of who their parents are or where they were born. If that liberty is to be restricted, it should be only if the people in question pose some grave danger that cannot be addressed in other ways. And, in such extreme situations, native-born people's liberty could potentially be restricted, as well. I develop these points in greater detail in Chapters 5 and 6 of my book Free to Move: Foot Voting, Migration, and Political Freedom.
Obviously, under current circumstances, citizenship includes not only the right to live and work in the US, but also rights to vote, hold public office, and receive various welfare benefits. In an ideal system, restrictions on voting and office-holding would be based on competence and (in some cases) there might be exclusions based on a demonstrated danger to liberal democratic institutions (as with Section 3 of the Fourteenth Amendment, which the Supreme Court wrongly gutted, to a large extent). We already have some competence-based constraints on the franchise, such as excluding children, some convicts, and immigrants who cannot pass a civics test most native-born Americans would fail if they had to take it without studying.
Access to welfare benefits should, I believe, be much more severely limited than is currently the case for both immigrants and natives. But even now the vast majority of immigrants contribute more to the public fisc than they take out, and limiting the welfare state is a bad argument for immigration restrictions that - if applied consistently - would also justify severely restricting many other liberties.
Thus, the ideal political system would have a strong presumption against restrictions on migration, while also imposing competence-based constraints on voting rights and office-holding, and limiting welfare benefits in various ways. We need some combination of decoupling citizenship from freedom of movement, constraints on access to government power, and limiting welfare benefits to a class of people who genuinely cannot avoid severe privation without them. And none of these rights and privileges should be, to any great extent, based on parentage or place of birth.
But, obviously, there are serious questions about whether governments can draw these lines in the right places and be trusted not to abuse their powers. Elsewhere, I have argued that we probably cannot rely too much on competence-based restrictions on the franchise, because real-world governments generally cannot be trusted in this field. We should instead address the problem of voter ignorance and bias by other means. It is also obvious that we are not going to get anywhere close to full freedom of movement for migrants anytime soon.
For these kinds of reasons, I think birthright citizenship for all people born in the United States is the best available option at this time. That's especially true because it does not preclude creating and expanding other pathways to residency, work rights, and citizenship. But we should be under no illusion that it is anywhere close to ideal, and we should remember that it includes an important element of unjust discrimination based on arbitrary circumstances of birth.
In this case, as with other situations involving unjust discriminatory immigration restrictions, the right approach to arbitrary discrimination is to "level up" rather than "level down." We should not deny birthright citizenship to those who currently enjoy its benefits. But we should also do all we can to expand these opportunities to others.
4/4/1861: Justice John McLean dies.

What’s on your mind?
A short excerpt from an opinion by Judge Rebecca Pennell (E.D. Wash.) Wednesday n Riera v. Central Wash. Univ.:
Mr. Riera was employed in a fixed term, non-tenure track faculty at Central Washington University (CWU)…. On the morning of April 1, [2024,] Mr. Riera called the CWU police to report an older, "apparently homeless," woman wandering around Samuelson Hall. He said he wanted to make a report "before things get … out of control." An officer reported to Samuelson Hall and confirmed the identity of the woman as a CWU professor. No further action was taken by campus police or Mr. Riera.
The CWU professor shared her experience with two colleagues. The colleagues immediately filed bias complaints with CWU, alleging the target of Mr. Riera's call—a Black woman—had been the victim of racial profiling.
This led to a great deal of institutional response, including a discussion at a faculty senate meeting. Defendant Erdman, "a lecturer at CWU and member of the faculty senate, emailed unofficial minutes [of the meeting] to non-tenured faculty," and her notes included this:
Brotherly crooks, dueling bourbons, and a law from 1785.
Please enjoy the latest edition of Short Circuit, a weekly feature written by a bunch of people at the Institute for Justice. Read More
4/3/1962: Engel v. Vitale argued.
What’s on your mind?
And then Trump sat next to Bondi for an hour of oral argument.
April 1, 2026 was an even busier day than I expected. The New York Times reports:
On Wednesday, the 60-year-old Ms. Bondi, downcast but determined, joined Mr. Trump for a glum crosstown drive to the Supreme Court, where they watched arguments in the birthright citizenship case. In the car, Mr. Trump told her it was time for a change at the top of the Justice Department.
Ms. Bondi hoped to save her job or, at the very least, buy a little more time — until the summer — to give herself a graceful exit.
She ended up with neither, and grew emotional Wednesday in conversations with friends and colleagues after she realized she was out. The next morning, Mr. Trump made it official, and fired her via social media post.
Bondi then sat next to Trump for nearly an hour. Several reports indicated that Trump sat emotionless during the oral argument. But what was Bondi's demeanor?
Life comes at you fast.
The case will be argued April 27th.
Yesterday, I submitted this brief as amicus curiae in United States v. Chatrie, the Supreme Court's case on the Fourth Amendment implications of geofencing and geofence warrants. You can get all of the briefs and materials in the case here. I'll probably blog about the case over the next few weeks, but for now I just wanted to flag my amicus brief. Here's the Summary of Argument:
The challenge of new technology is a recurring theme in Fourth Amendment law. This case raises a host of new and important questions, and this brief hopes to help frame the issues and provide directions for answering them.
The first set of questions considers whether obtaining Chatrie's Location History records was a Fourth Amendment "search" of his "papers." There are two different arguments to evaluate. The first is the virtual private locker question. Did Chatrie store his Location History records in a virtual private locker with Google, such that he had Fourth Amendment rights in the contents of the virtual locker just as he would with an equivalent physical locker? This brief concludes that the answer is likely no. Although the record is murky on the point, Chatrie likely lacked the control over the records needed to have Fourth Amendment rights in them.
The second search argument considers whether Chatrie had Fourth Amendment rights under the limits placed on the third-party doctrine by Carpenter v. United States, 585 U.S. 296 (2018). This brief argues that he did not. Carpenter does not apply because Chatrie voluntarily opted in to have Google create and store his Location History records.
The next set of issues considers the lawfulness of the warrant, assuming that one was needed. The brief argues that a properly drawn geofence warrant can satisfy the Fourth Amendment. The Fourth Amendment does not present an all or nothing choice between zero protection and absolute protection. Where the law requires a warrant, it also provides a means to draft a lawful warrant.
On the specifics of the warrant in this case, the warrant was properly drawn as to Step 1 because it was sufficiently narrow in both time and space. The constitutionality of the warrant at Step 2 is uncertain, however. It is not clear that the Fourth Amendment allows multi-stage warrants, and the particularity of Step 2 debatable. Chatrie may not have raised these issues as to Step 2, however, so they may be waived.
The fact that this case reaches the Court so late in the Term, and that it raises so many complex issues, suggests that there may be value in pointing to a resolution that might plausibly reach consensus. If so, amicus suggests that the Court might want to resolve this case by focusing primarily on the warrant issues. The legality of the warrant implicates fewer contested questions and has a more complete factual record. For the sake of completeness, however, this brief covers both issues.
Just in time for a Congressional vote this month on reauthorization of the vital intelligence program
The Privacy and Civil Liberties Protection Board (PCLOB) has just released a comprehensive staff report on section 702 of the Foreign Intelligence Surveillance Act (FISA). Since Congress must reauthorize section 702 or let it die this month, the report could hardly be more timely. And its conclusions make a strong case for reauthorizing the provision.
The report is also a fount of information about how section 702 and the statutory changes adopted in 2024 are working.
All in all, the PCLOB report provides a detailed picture of section 702 as it stands today. It may be particularly valuable to members of Congress who didn't want to support reauthorization without an assurance that this administration was implementing the 2024 act's reforms in good faith. The PCLOB report leaves little doubt on that score.
From Foster v. Nestle USA, Inc., decided Tuesday by Judge Steven Seeger (N.D. Ill.):
Stephanie Foster has a sweet tooth, and she wanted to sink her teeth into a mouthful of chocolate. By the sound of things, Foster is a foodie. She didn't want just any chocolate. She wanted 100% real chocolate.
Foster went shopping at nearby Target and Jewel Osco stores, searching for the best that the cacao bean had to offer. She bought several bags of chocolate chips manufactured by Nestle USA, Inc…. Each bag had a label promising any hungry consumer that the bag contained "100% real chocolate." …
Foster apparently was none too pleased when she realized that the chocolate chips contained soy lecithin and natural flavors. As Foster sees things, chocolate that contains soy lecithin and natural flavors isn't "100% real chocolate." In fact, it's not chocolate at all. So Foster brought Nestle to federal court. She sues on behalf of herself and a putative class [on various misrepresentation-related theories].
For the reasons below, the motion to dismiss is granted. The complaint is half-baked, and is 100% dismissed….
From Judge Christopher Cooper's opinion Tuesday in Johnson v. Georgetown Univ. (D.D.C.):
Plaintiff Aneesa Johnson, an African American and Muslim woman of Palestinian origin, alleges that Georgetown discriminated against her when it fired her [from her position as Assistant Director of Academic and Faculty Affairs at Georgetown's Walsh School of Foreign Service] after discovering eight-year-old social media posts that described her "hat[red]" for Zionists.
{Three of Johnson's posts are relevant here. The first read, "Ever since going to [Northwestern] I have a deep seeded [sic] hate for Zio bitches. They bring out the worst in me." The second elaborated, "You know why I call them Zio bitches, because they're dogs." And the third post was a repost of another user's Tweet, which included a photograph of a scowling Orthodox Jewish man with the caption, "When the whole world hates you bc you a thief and grow up looking like a shaytan #GrowingUpIsraeli." ("Shaytan" means devil or demon in Arabic.)}
She also brings a bevy of related hostile work environment, retaliation, and tort claims against Georgetown and a constellation of other defendants, including Rachel Jessica Wolff and Ilya Shapiro, individuals who publicized Johnson's old posts on Twitter; Canary Mission, a controversial organization that creates online profiles of students and professors on college campuses who have been critical of Israel; and a handful of Canary Mission's donors….
Upon consideration of the voluminous set of briefs in this case, the Court concludes that Ms. Johnson's claims against the movants must be dismissed with prejudice. Among myriad grounds for dismissal, the complaint does not make out any claim that Johnson was discriminated against based on her race, religion, or national origin, nor can she proceed in tort against Georgetown or other defendants due to procedural and substantive defects in her claims….
The opinion is over 20K words long, and I can't do it justice here. But I thought I'd pass along this passage, which is relevant to some of the First Amendment / tort law discussions we've had on this blog in past years:
Another religious freedom case in a free speech guise
The Supreme Court ruled this week, 8-1, in Chiles v. Salazar, that Colorado may not apply its ban on conversion therapy for minors to prohibit a licensed counselor's talk therapy. Justice Gorsuch wrote for the Court; Justice Kagan concurred, joined by Justice Sotomayor; Justice Jackson dissented. The Court held that, as applied to therapist Kayla Chiles's conversations with clients, Colorado's law discriminates on the basis of viewpoint and therefore triggers the most searching First Amendment scrutiny.
A couple points. First, this is not, formally speaking, a religion case. It's a Free Speech Clause case. Indeed, as far as I can tell, the word "religion" does not even appear in the Court's opinion. But the case is religion-adjacent. Chiles described herself in the litigation as a practicing Christian whose views about sex and gender are informed by her faith, and she said that some clients seek her out because they want counseling consistent with those convictions. So although religion is not part of the Court's doctrinal analysis, it is very much part of the background.
That feature places Chiles in a familiar line of First Amendment cases. Think of 303 Creative, another Gorsuch opinion. Or Barnette, the WWII-era flag salute case. Both were free speech cases in doctrinal terms, but religious conviction supplied much of the underlying human drama. One sees something similar here. Disputes touching religious freedom often come to the Court not under the Religion Clauses, but in the guise of free speech. Religion influences what people say--or don't say.
The key to the Court's reasoning is viewpoint discrimination. Colorado's law allows counseling that affirms a minor's sexual orientation or gender identity, but forbids counseling that seeks to help a minor change or redirect sexual orientation or gender identity. For the Court, that means the State is not simply regulating treatment as such. It is permitting one side of a contested moral and psychological question while suppressing the other. That, the Court says, is about as serious a First Amendment problem as one can have.
Second, it's notable how little work the formal strict-scrutiny framework seems to do once the Court reaches that conclusion. The Court says that content-based restrictions ordinarily trigger strict scrutiny, and that viewpoint discrimination is an especially egregious form of content discrimination. But it does not linger over the familiar steps of balancing: compelling interest, narrow tailoring, least restrictive means. Instead, once the Court identifies viewpoint discrimination, the case is largely over. The rest of the opinion is devoted mostly to rejecting Colorado's efforts to characterize the law as regulation of professional conduct rather than speech. Chiles thus resembles 303 Creative in this way as well. In 303 Creative, too, the Court avoided applying the strict-scrutiny balancing test in a serious way.
For those interested, I discuss Chiles in a short Legal Spirits episode, here.
4/2/1980: Justice Stanley Forman Reed dies.

What’s on your mind?
The legal landscape for transgender cases has changed since 2023.
Back in August 2025, I speculated about why the Court granted certiorari in Chiles v. Salazar, yet denied review two years early in Tingely v. Ferguson, an identical case from the Ninth Circuit. I queried, "Perhaps the climate of the day on transgender issues, in the wake of Skrmetti, make this issue more palatable?"
On Tuesday, the Court decided Chiles. The 8-1 vote was quite lopsided. Only Justice Jackson was in dissent. She articulated a very cramped conception of free speech in the commercial context. Justices Kagan and Sotomayor joined the majority opinion in full. They even wrote that Jackson "reimagin[ed]—and in that way collaps[ed]—the well-settled distinction between viewpoint-based and other content-based speech restrictions." I think Kagan and Sotomayor were correct. Indeed, it was very significant they felt compelled to respond forcefully to Justice Jackson. There have been press reports of how Justice Kagan and Sotomayor are unhappy with Justice Jackson. This opinion may represent those tensions boiling over.
Given that this case was so straightforward, why didn't the Court grant Tingley in 2023. The legal issues are the same. There has been no intervening free speech precedent.
I would posit that the legal landscape for transgender cases has changed since 2023. President Trump's executive order from January 2025, rejecting the entire concept of gender identity, reflects a broader societal shift. In the span of about a year, the Court will have decided Skrmetti, Mahmoud, Chiles, Mirabelli, and the Title IX case. While Srkmetti and Mahmoud split 6-3, I think the Title IX case may also be lopsided. Based on the oral argument, Justice Kagan seemed sympathetic to the view that Title IX bars biological males in female sports.
The legal landscape for transgender cases has shifted since 2023. Most Americans, and even legal elites, see a distinction between gay and lesbian rights and transgender rights. You can support gay marriage but oppose providing puberty blockers to minors. You can support gay troop leaders but oppose drag queen storytime. You can oppose electro-shock therapy for gay teens and also oppose public schools secretly transitioning teens without telling parents. You can oppose firing a person because they're gay but favor excluding biological males from female spas. And so on.
I've never fully understood why LGB was merged with T. Sexual orientation and gender identity are such different concepts. For gays and lesbian people, the mantra is "we were born this way, so accept us as we are" But for transgender people, the message is the opposite: "we were not born this way, so accept us as we tell you we are."
I think the schism between LGB and T is now inevitable. At some point, gay rights groups might re-evaluate their priorities.
Help Reason push back with more of the fact-based reporting we do best. Your support means more reporters, more investigations, and more coverage.
Make a donation today! No thanksEvery dollar I give helps to fund more journalists, more videos, and more amazing stories that celebrate liberty.
Yes! I want to put my money where your mouth is! Not interestedSo much of the media tries telling you what to think. Support journalism that helps you to think for yourself.
I’ll donate to Reason right now! No thanksPush back against misleading media lies and bad ideas. Support Reason’s journalism today.
My donation today will help Reason push back! Not todayBack journalism committed to transparency, independence, and intellectual honesty.
Yes, I’ll donate to Reason today! No thanksSupport journalism that challenges central planning, big government overreach, and creeping socialism.
Yes, I’ll support Reason today! No thanksSupport journalism that exposes bad economics, failed policies, and threats to open markets.
Yes, I’ll donate to Reason today! No thanksBack independent media that examines the real-world consequences of socialist policies.
Yes, I’ll donate to Reason today! No thanksSupport journalism that challenges government overreach with rational analysis and clear reasoning.
Yes, I’ll donate to Reason today! No thanksSupport journalism that challenges centralized power and defends individual liberty.
Yes, I’ll donate to Reason today! No thanksYour support helps expose the real-world costs of socialist policy proposals—and highlight better alternatives.
Yes, I’ll donate to Reason today! No thanksDonate today to fuel reporting that exposes the real costs of heavy-handed government.
Yes, I’ll donate to Reason today! No thanks