Congratulations to Sam Bray, Whose National Injunction Article Was Cited Three Times by Justices Today

That happened in yesterday's opinions respecting the stay in Labrador v. Poe, twice in Justice Gorsuch's concurrence (joined by Justices Thomas and Alito), and once in Justice Jackson's dissent (joined by Justice Sotomayor). Nice! For Sam's substantive analysis of Labrador, see this post.

Comments

[John F. Carr]

The citation in the dissent:

Nor does history offer an easily discernible answer. As one leading scholar candidly admits, “traditional equity lacked the sharply defined rule” that the concurrence would claim the Court adopted today. S. Bray, Multiple Chancellors: Reforming the National Injunction, 131 Harv. L. Rev. 417, 421 (2017).