The Volokh Conspiracy

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Guns

Deliberately Arming Oneself to Answer Door to Police May Be "Privileged" Against "Obstructing Official Business" Prosecution

But I wouldn't recommend it.

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From State v. Conrad, decided Monday by the Ohio Court of Appeals, in an opinion by Judge Eugene Lucci, joined by Judges Matt Lynch and Scott Ylnch:

In 2025, Conrad was living with his girlfriend and their ten-month-old son in Conrad's home in Wickliffe, Ohio. In April 2025, Conrad and his girlfriend were involved in a verbal altercation. After the girlfriend allegedly damaged Conrad's PlayStation console in the basement, Conrad called 911. He informed the dispatcher that he would be armed "because the cops are coming in here." The dispatcher responded, "Do not pick it up with your hands, okay?" Conrad stated, "Absolutely." After ending the 911 call, Conrad armed himself by holstering a handgun on his right hip and then went upstairs to await law enforcement.

When the first officer arrived, Conrad observed him approaching the front door on foot, at which point Conrad opened the door for the officer and informed him that he was armed. The officer responded by stating "pardon me" or "excuse me," and Conrad responded again that he was armed. The officer saw the firearm on Conrad's hip and informed him that he was going to relieve him of the gun. Conrad initially refused, stating, "No you're not," and he changed his stance by turning his right hip away from the officer. Conrad then motioned to or placed his hand on his gun, at which point the officer drew his own firearm. After loudly arguing as to whether Conrad was permitted to be armed, Conrad raised his hands and told the officer to take his gun. Approximately 23 seconds elapsed between the officer entering the home and the officer disarming Conrad.

After disarming Conrad, the officer spoke with him for several minutes regarding his decision to arm himself. During this conversation, Conrad indicated he had armed himself because he believed men were typically arrested when police were called for domestic matters, and he wanted to "eve[n] the playing field" because he was unsure how officers would respond and did not trust them. After speaking with Conrad, the first responding officer joined other officers who had arrived and were speaking to Conrad's girlfriend in the basement. The girlfriend indicated that Conrad had pushed her, and she fell back, bumping her hip against a table, during their dispute.

Conrad was acquitted of domestic violence, but convicted of violating R.C. 2921.31(A), which provides:

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How Did Support for International Humanitarian Law and Norms Morph into Support for Hamas and its Goals?

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At his Substack, Shany Mor reflects on the revealed preferences since 10/7 of the Western NGOS, individuals, and governmental institutions "united by loosely overlapping commitments to global and transnational justice." This group, which he dubs "Humanitarians," could have responded to 10/7 in one of four general ways:

H1: Humanitarians, especially including scholars of international law regarding armed conflict, are neutral regarding the belligerent parties in the war, and the Humanitarians collectively are genuinely committed to the humanitarian needs of civilians and noncombatants among both Israelis and Palestinians.

H2: Humanitarians are indifferent to the humanitarian needs of the Israelis but genuinely committed to the humanitarian needs of the Palestinians. Operating on imperfect information in rapidly changing conditions, and limited by what is allowable in international law and what is politically or materially feasible, they seek whatever can be done to reduce or eliminate loss of life or suffering on the part of Palestinians either as a direct or indirect consequence of the war.

H3: Humanitarians are indifferent to the immediate humanitarian needs of Palestinian civilians, but they fervently wish to see Israel defeated in the war Hamas started on October 7. They fervently believe that the only moral conclusion to the war is one that is a net gain for the Palestinians and a net loss for the Israelis. To this end, they endeavor to act as force multipliers both in theatre to preserve Hamas' power and, especially, in Western states, to push for policies that limit Israel's freedom of action, cut it off from military supplies, and apply pressure on it.

H4: Humanitarians are indifferent to the war's strategic outcome and prefer to see more death and more suffering on the Palestinian side, not as an end in and of itself but rather as a means to confirm beliefs in Israel's essentially demonic nature, and as a way of mobilizing hatred and social isolation of Jews in the West. In particular, there is a preference for any rhetoric or political action which removes what are believed to be the unfair social privileges which western Jews hold due to the memory of the Holocaust.

As Mor elaborates: "Overwhelmingly … the majority of the real-life actions of the Humanitarians are in line with the predictions of H3, with a substantial minority also in line with H4. More strikingly, only a tiny amount are plausibly aligned with H2 and virtually none with H1."

This isn't news to anyone who has been paying attention, but it does beg the question: why? Why did concern about international humanitarian law and norms morph into support for Islamist terrorist groups and visceral hatred for Israel and often Jews in general, and a general lack of concern for the actual humanitarian needs even of the side they implicitly or explicitly support (H2)?

The simple answer is that the movement was taken over by a far left strongly influenced by a combination of anti-Western "anti-colonialist" theory and the massive investment of the late USSR is spreading "antizionist" propaganda. But how and why did the relevant institutions, once proudly "liberal" in the broad sense (e.g., Amnesty International and Human Rights Watch) get taken over by the far left? There is a good book to be written on this, if anyone is so inclined.

Copyright

Odd January 6 Trial Follow-On: Copying Expert's Report from Another Case, to File It in Your Case, May Infringe Copyright

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From Olson v. McBride Law Firm, PLLC, decided yesterday by Judge Naomi Reice Buchwald (S.D.N.Y.); seems correct to me:

In April 2022, plaintiff [Lindsay Olson] prepared an expert report titled "Multi-District Comparative Community Attitude Study" (the "Report") at the request of two attorneys representing two criminal defendants charged in the "Oath Keepers" trial, which arose from charges against members of the Oath Keepers, an organized militia group that participated in the January 6, 2021 attack on the U.S. Capitol. The Report, prepared for use in support of motions to transfer venue, analyzed potential bias in the District of Columbia jury pool against defendants prosecuted for conduct arising from the January 6, 2021 attack and concluded that "the DC Community is saturated with potential jurors who harbor actual bias" against those defendants.

For a fee of $30,000, plaintiff licensed the Report to the two attorneys who commissioned it, authorizing its use in support of venue transfer motions. In April 2022, the attorneys filed the Report on the public docket in the "Oath Keepers" case in support of a motion to transfer venue.

Defendant Joseph D. McBride and his law firm, McBride Law Firm, PLLC, represented Richard Barnett, a defendant in a separate criminal case also arising from the January 6 Capitol attack. In September 2022, defendants obtained a copy of the Report, without plaintiff's authorization and without paying a licensing fee, and filed it in its entirety in United States v. Barnett, No. 1:21-cr-00038, as an exhibit in support of a motion to transfer venue….

Olson sued for copyright infringement, and the court denied a motion to dismiss. The court held that plaintiff had plausibly alleged that defendant's use was presumptively infringing:

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Fired U.S. Attorney In Washington Files Case That Should Overrule Whatever Remains Of Morrison v. Olson

Justice Scalia was right. Federal courts should not be allowed to appoint federal prosecutors who cannot be fired.

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Randy Barnett and I recently finished maxing out (to use the lingo of the day) the Separation of Powers chapter for the Fifth Edition of our casebook. We went back-and-forth about whether it was even necessary to keep Morrison v. Olson. Ultimately we decided to, in large part, because Chief Justice Rehnquist explains the line of precedents from Myers to Humphrey's Executor. Moreover, Justice Scalia's iconic dissent would later be vindicated in Slaughter. Students should not forget how we got to the present moment.

Still, we recognized that very little of Morrison survived. The Independent Counsel statute, as well as the special prosecutor regulations, barely survived Trump v. United States, and are dead after Slaughter. But one facet of Morrison remains: can federal judges appoint prosecutors who are not subject to presidential removal. Now, there is a case to overrule that last glimmer of Morrison.

The U.S. District Court for the Western District of Washington appointed Roger Rogoff as United States Attorney. Trump promptly fired Rogoff. Now Rogoff has sued Trump, seeking a preliminary injunction to invalidate the "purported removal." Rogoff argues that Trump's firing violates the Appointments Clause, even after.  Slaughter.

Slaughter is not to the contrary because it did not address the propriety of removal protections for inferior officers. Before Slaughter, the Supreme Court had long recognized "two exceptions" to the general rule that the President enjoys unbounded removal power: the first authorized Congress to "provide tenure protections to certain inferior officers," and the second to limit removal in "expert agencies led by a group of principal officers." Seila Law, 591 U.S. at 204 (emphases omitted). Slaughter eliminated the latter but left the former in place. 2026 WL 1855612 at *15, *18 ("Nor do we determine the fate of officials not before us.").

And I call attention to Footnote 1 of the brief:

U.S. Attorneys are not the only Executive Branch prosecutors the Judiciary appoints. Historically, they have (on application) appointed independent counsel. 28 U.S.C. § 593; Morrison v. Olson, 487 U.S. 654, 676 (1988) ("[W]e do not think it impermissible for Congress Case 2:26-cv-02566 Document 8 Filed 07/21/26 Page 11 of 32 to vest the power to appoint independent counsel in a specially created federal court."). They likewise appoint special prosecutors pursuing criminal contempt. See Young v. U.S. ex rel. Vuitton et Fils S.A., 481 U.S. 787, 793 (1987) ("[I]t is long settled that courts possess inherent authority to initiate contempt proceedings for disobedience to their orders, authority which necessarily encompasses the ability to appoint a private attorney to prosecute the contempt."); see also United States v. Donziger, 38 F.4th 290, 294 (2d Cir. 2022) (appointment of special counsel by court did not violate separation of powers).

Yeah, about that. Morrison is not long for this world. The Second Circuit's decision in Donziger was wrong. Hey, if Justice Gorsuch and Steve Vladeck agree, they can't both be wrong! And I dare Judge Boasberg to appoint a private attorney to prosecute DOJ officials. He would deserve that benchslap.

Federal judges should not be allowed to make appointments to the executive branch--especially United States attorneys who cannot be fired by the President. Moreover, I am not at all convinced U.S. Attorneys are actually "inferior" officers. Lower courts have reached this holding with very conclusory logic, but the Supreme Court has never settled the issue.

If there is a conflict between the executive branch and congress, it should not fall to the judicial branch to resolve the matter.

I would expect the judges of this District Court to recuse, so some other well-meaning Washington judge will rule against Trump. And the Ninth Circuit will issue a decision that should be reversed.

"So You're About to Start Law School"

A video lecture for entering 1Ls.

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Last year, I recorded a 41-minute talk for incoming law students on how to approach the first month of law school.  It's targeted at students who don't know much about how law school works, with the hope that they can start school more informed about the weird ways of studying law.  You can watch it here:

 

Chief Justice Roberts Broke The Fourth Wall in Cook

This unusual opinion suggests something happened behind the scenes over the past ten months.

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For years, Justice Kagan was overtly critical of the Supreme Court's approach to emergency applications. In written dissents and public speeches, Kagan fed into the nefarious "shadow docket" narrative. She may as well have blurbed Steve Vladeck's book. Yet, I've noticed over the past year or so that rhetoric from Justice Kagan has faded. Indeed, Kagan testified that she would rather "not now . . . call it the shadow docket . . . because we have done . . . a better job . . . where appropriate [of] explaining ourselves, at least to a moderate degree." Kagan added, "we have gotten more experienced in these constant requests that are coming to us about requests for emergency relief . . . and we have issued opinions, and sometimes majority and dissenting opinions accordingly."

Kagan was almost certainly referring to Trump v. Cook, which might be the slowest emergency docket case of all time. Remember, President Trump purported to remove Governor Lisa Cook from the Federal Reserve on August 25, 2025. Twelve days later the District Court granted a preliminary injunction. Four days after that, the D.C. Circuit denied the government's motion to stay. The case reached the Supreme Court on September 18, 2025. It would take the Court more than 280 days to decide the case in its "interim" posture, with more than 80 pages of majority, concurring, and dissenting opinions.

Justice Alito's dissent laid out the glacial chronology.

The President then applied for a stay from this Court. When that application arrived here, this litigation was just 21 days old. There had been only two rounds of abbreviated briefing below and no meaningful development of a factual record. Indeed, the record does not even contain copies of Cook's allegedly fraudulent mortgage applications. Of course, parties may appropriately seek (and courts may appropriately grant) stays early in a litigation. No court, including this Court, should sit on its hands when interim relief is appropriate. But this does not mean that the Court must reach out to opine on each issue that could conceivably arise in a case's future. Here, the incipiency of this case and the complexity of the issues that it presents counseled in favor of a light touch by this Court, regardless of whether we granted or denied the application. To that end, the Court should have resolved the President's application shortly after we received it. And in doing so, we should have focused on the few issues that the courts addressed below. If a majority had desired, we could have issued a statement explaining our decision. That is exactly how we have handled nearly all our stay applications in recent years.

Had the Court denied the stay in September or October of 2025, the lower courts could have proceeded to decide the case on the merits, and presented the Supreme Court with a regular appeal. But the Court (and by Court, I mean the Chief Justice) chose a different path. Alito explains further:

Although the panel performed admirably given the four days that it had to decide the President's stay motion, nobody can doubt that the panel would have produced more comprehensive opinions if it had even a fraction of the 280-plus days that this Court has spent with the case. Either way, this Court could have reentered the fray when we inevitably granted certiorari. Instead, the Court departed from its normal practice and "deferred" ruling on this application, bringing proceedings in the lower courts to a 9-month standstill. 606 U. S. 1062 (2025). We then ordered the parties to submit more briefing than they had filed at any other point in this litigation. In January, we held oral argument, marking just the second in-court proceeding in this entire suit. The Court now issues a full-length opinion that purports to resolve many complicated and novel legal questions on an underdeveloped record while ignoring lurking jurisdictional issues."Either out of humility or out of self-respect (one or the other), the Court should decline to answer" these "incredibly difficult" questions in this case's current posture. PGA TOUR, Inc. v. Martin, 532 U. S. 661, 700 (2001) (Scalia, J., dissenting).

Moreover, the Court reached out to decide several significant constitutional questions that were not necessary to decide. Is the Federal Reserve's so-called "independence" consistent with the separation of powers? Do the federal courts even have jurisdiction to review the President's termination of a Governor? Did Cook even have a "cause of action" to challenge her removal? Justice Barrett raises these, and other questions in her concurrence. But the Supreme Court was content to decide a landmark case on its "emergency" docket, leapfrogging over all prudence. This unusual posture was sure to placate Justice Kagan and the Court's critics, but is at odds with the Chief's self-professed modus operandi.

Indeed, something seems to have happened behind-the-scenes in this case. In most cases, the Chief Justice barely acknowledges the dissent, and offers sparse responses, if that. In Barbara, the dissents were more than five times as long as the majority. Roberts didn't care to respond because he had five votes.

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AI in Court

I've Seen Fake Cites on Both Sides Now (II)

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From Evans v. Robertson, decided today by Judge Judith Levy (E.D. Mich.) (for the original on the Magistrate Judge's September 2025 post decision in this case, see here):

Plaintiff and Defendant's objections will be stricken because they contain factitious citations.

The litigants in this case have been repeatedly warned that factitious citations will not be tolerated by the Court. Magistrate Judge Elizabeth A. Stafford ordered Plaintiff and Defendant to "include a written representation that [they have] personally checked each legal citation and each citation is accurate and stands for its asserted proposition" and warned that a failure to do so may result in sanctions. Despite Judge Stafford's order and this Court's repeated warnings, both Plaintiff and Defendant have violated the Court's express requirements numerous times.

On November 20, 2025, the Court imposed sanctions on both Plaintiff and Defendant for their repeated use of factitious citations and have stricken the parties' filings when they contain factitious citations. The parties have been warned that additional sanctions may be imposed if future filings contain factitious citations….

Plaintiff's objections contain factitious citations. Plaintiff declares in her objection that she "reviewed the citations and representations contained herein and that, to the best of [her] knowledge, information, and belief formed after reasonable inquiry, they are accurate and supported by the record." However, in her objections, Plaintiff argues,

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Civil Asset Forfeiture

Supreme Court Will Consider Excessive Fines Clause Asset Forfeiture Case

It will review Alaska's confiscation of a $95,000 plane arising from the pilot's illegal transportation of up to 72 cans of beer.

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Ken Jouppi. (Institute for Justice)

 

In Timbs v. Indiana (2019), the Supreme Court unanimously ruled that the Excessive Fines Clause of the Eighth Amendment is incorporated against state governments. It also ruled that asset forfeitures - confiscation of property that may have been used to facilitate commission of a crime - qualify as fines. But it gave little guidance on what exactly qualifies as "excessive." This lack of clarity stimulated all sorts of uncertainty and disagreement in lower state and federal courts.

Recently, the Court decided to hear the case of Jouppi v. Alaska. Jouppi is an Alaska "bush pilot," flying passengers to remote areas. In 2012, Alaska authorities caught him transporting a passenger who had 72 cans of beer with her, to a "dry" village where importation of alcohol is banned. State law criminalizes transportation of alcoholic beverages there.

For this crime, Jouppi was fined $1500 and sentenced to three days in jail. But the state then used its asset forfeiture law to confiscate Jouppi's plane (worth about $95,000). There is some dispute about whether Jouppi was aware of all 72 cans, or just the one six-pack that was visible. But the Alaska Supreme Court concluded this issue is irrelevant, because courts must heavily defer to the legislature on the issue of what qualifies as a serious enough offense to justify massive forfeitures, and "[i]t is clear to us that the legislature determined that the harm from even a six-pack of beer knowingly imported into a dry village is severe enough to warrant forfeiture of an aircraft."

I think it is obvious that even the illegal transportation of 72 cans of beer (let alone just six) is nowhere near severe enough an offense to justify forfeiture of a plane worth $95,000. In a previous case, the Supreme indicated that a fine is "excessive" if it is "grossly disproportionate" to the "gravity" of the underlying offense. That's far from a clear standard, and the Court should flesh it out in greater detail. But if the Jouppi forfeiture is not "grossly disproportionate," I do not know what is.

In addition, the Alaska Supreme Court was wrong to rule that courts must give the legislature broad deference on such issues. That defeats the whole point of the Excessive Fines Clause, which is to limit legislative power. By this logic, the legislature could exempt almost any fine from invalidation so long as it claims the underlying offense is really, really bad. You could, for example, justify the forfeiture of a $1 million  house because the owner used it to store an illegally purchased cigarette. Indeed, that fact pattern isn't so much worse than what happened in Jouppi!

The Alaska Supreme Court's reasoning is another example of the tendency of many jurists to defer to the legislature on property rights issues in a way they would never accept when it comes to other constitutional rights. The Kelo "public use"  takings case is a particularly notorious example of this problem.

There are other problems with the Alaska Supreme Court's decision. Its reasoning about the severity of the crime here is not premised on any notion that illegal transportation of alcohol is itself a grave offense, but that it indirectly contributes to excessive drinking, which in turns leads to crime and social pathology in rural parts of Alaska, where (as the lower court found) law enforcement has limited resources to deal with it.

This whole chain of reasoning is extremely dubious. The experience of the Prohibition era showed that prohibiting alcohol sales is a poor strategy for combating crime, and indeed actually exacerbates it, by facilitating the rise of organized crime and its associated violence. And if the problem is that Alaska law enforcement has too few resources to deal with crimes arising from alcohol abuse, then it shouldn't be wasting those scarce resources on the less effective tactic of enforcing prohibition! Instead, have more cops on the beat actually targeting violent crime.

These last few points might be seen as policy considerations, normally left to the legislature. But courts should scrutinize them if - as in this case - they are part of the government's rationale for arguing that the fine here is not "excessive." In that event, the accuracy of the state's claims is relevant to the court's resolution of the constitutional issue before it.

Jouppi is represented by the Institute for Justice, the libertarian-leaning public interest law firm that also successfully litigated the Timbs case. I am guardedly optimistic they will prevail here, too. If we are lucky, the Court might  in the process establish a clearer and more restrictive standard for what qualifies as an "excessive" fine. But, all too often,  these kinds of predictions aren't worth much more than what you're not paying for them!

NOTE: As indicated above, Jouppi is represented by the Institute for Justice. I have longstanding connections with IJ, and for which I have done pro bono work on other property rights cases. I did not, however, have any involvement in this case. IJ has an informative website devoted to the Jouppi case here.

 

Did no one else notice Justices Kagan and Barrett's Sartorial Choices?

Kagan was in red and Barrett was in blue!

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I apologize for the light blogging of late. Well, light for me at least. Randy and I just submitted the final chapter of the Fifth Edition of our casebook to the publisher. It took us nearly two weeks to figure out how to present Trump v. Barbara. I think we figured out a really innovative and accessible way of presenting the different issues, so students can easily contrast the majority and dissenting opinions. We hope to share an excerpt once the page proofs are ready.

I still have not finished reading all of the opinions from the end of the term. Plus, I have a host of half-finished posts about Slaughter, Cook, Barbara, the TPS case, West Virginia v. B.P.J., and more. I hope to get those done over the next few weeks. (I could not resist dumping on the "Aloha spirit" breaking news.)

Now, as I slowly climb out of the backlog, let me highlight something that I was surprised didn't get much attention: Justice Kagan and Barrett's sartorial choices.

Did no one else notice that Justice Kagan was wearing a bright red suit while Justice Barrett was wearing a dark blue suit? You see, the colors are reversed! I suppose this could have been coincidental. I found a few photos of Kagan wearing red in the past. Still, I'd like to think this was a subliminal attempt at bipartisanship.

I agree with David Lat and others that Kagan and Barrett are the perfect spokespersons for the Court at this moment. I wrote an essay that should be out this summer about why the Justices should hold regular press conferences to help rehabilitate the public's image. Kagan and Barrett should be the first ones to the mic.

Academic Freedom

New Academic Freedom Podcast on Pernell Decision

A conversation with a lead attorney for one of the most significant academic freedom cases in recent years

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A new episode of the Academic Freedom Podcast has been released. The podcast is sponsored by the Academic Freedom Alliance and the Center for Academic Freedom and Free Speech at Yale Law School.

This episode features a conversation with Greg Greubel, a senior attorney at the Foundation for Individual Rights and Expression (FIRE) and one of the lead attorneys who argued the case against Florida's Stop W.O.K.E. Act restrictions of faculty speech in public university classrooms. The 11th Circuit just handed down an opinion in that case, Pernell v. Florida Board of Governors. It is one of the most consequential academic freedom cases of recent years.

In the new podcast episode, we discuss the case and its background, break down the First Amendment law surrounding academic freedom issues at public universities, and consider some of the implications of this decision for future cases, including ongoing litigation arising out of "divisive concepts" policies in Alabama and Texas. Give it a listen here.

Israel's Changing Strategic Calculus

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As someone whose views once fit the description of the Oslo-and-beyond era Israeli security establishment view, I found this analysis, from Nahum Kaplan, compelling:

For much of the period after the 1993 Oslo Accords, a powerful current within Israel's political and security establishment rested upon several interconnected propositions.

The lists includes: that Palestinian institutions could gradually become responsible governing partners, economic prosperity would reduce enthusiasm for violence, technological superiority and superior intelligence could contain threats that could not be eliminated, limited military operations could reduce enemy capabilities while avoiding the political cost of decisive confrontation, and international diplomacy, though frequently frustrating, remained indispensable to long-term security.

None of these ideas was entirely absurd. That is precisely why they were so influential….

Besides breaching the border, Hamas breached an entire conceptual architecture. The massacres, hostage-taking, and temporary collapse of Israel's local defences shattered public faith in the proposition that a genocidal movement could be indefinitely managed through surveillance, economic concessions, and occasional bombardment. A sophisticated intelligence apparatus had produced an unsophisticated conclusion: The enemy did not really mean what it repeatedly said.

This is one of the West's more persistent strategic pathologies. It interprets ideological conviction as theatrical language, then expresses astonishment when zealots proceed to act upon it. Western governments frequently assume that everybody ultimately wants what Western officials want: stability, prosperity, recognition, improved trade, and a favourable paragraph in the communiqué.

Some people want victory, domination, and to kill you for who you are. The inability to comprehend this does not make one humane. It makes one vulnerable.

As they say, read the whole thing.

More

Recent Volokh Posts

1

U Tennessee Track & Field Head Coach Seeks Preliminary Injunction Against "Untruthful, Derogatory and Offensive Statements" Plus More Commentary

2

Deliberately Arming Oneself to Answer Door to Police May Be "Privileged" Against "Obstructing Official Business" Prosecution

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How Did Support for International Humanitarian Law and Norms Morph into Support for Hamas and its Goals?

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Odd January 6 Trial Follow-On: Copying Expert's Report from Another Case, to File It in Your Case, May Infringe Copyright

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Today in Supreme Court History: July 22, 1937

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Open Thread

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Fired U.S. Attorney In Washington Files Case That Should Overrule Whatever Remains Of Morrison v. Olson

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"So You're About to Start Law School"

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Chief Justice Roberts Broke The Fourth Wall in Cook

10

I've Seen Fake Cites on Both Sides Now (II)

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