{"id":380,"date":"2026-07-14T14:09:53","date_gmt":"2026-07-14T14:09:53","guid":{"rendered":"https:\/\/americanservicereview.com\/?p=380"},"modified":"2026-07-14T14:09:53","modified_gmt":"2026-07-14T14:09:53","slug":"two-cheers-but-not-three-for-roberts-and-barrett","status":"publish","type":"post","link":"https:\/\/americanservicereview.com\/?p=380","title":{"rendered":"Two cheers \u2013 but not three \u2013 for Roberts and Barrett"},"content":{"rendered":"
\n

Chief Justice John Roberts and Justice Amy Coney Barrett deserve high praise for the pivotal role they played at the end of the just-concluded term in two key cases.<\/p>\n

Read more The biggest Supreme Court surprises this term<\/a><\/p>\n

One is Trump v. Barbara<\/em>, the monumental decision confirming that the equal protection clause of the 14th Amendment guarantees birthright citizenship. Roberts and Barrett were joined by the court\u2019s three liberals to make a bare five-member majority for the chief justice\u2019s opinion. The other four justices all rejected the court\u2019s constitutional ruling, including Justice Brett Kavanaugh, who accepted that a statute conferred citizenship on virtually all children born in the United States (excluding only the children of foreign diplomats, or others in even rarer instances where U.S. law does not apply on U.S. soil) but who also concluded that the Constitution gives Congress the authority to narrow the scope of U.S. citizenship by virtue of birth in the U.S.<\/p>\n

The other of these two cases is Watson v. Republican National Committee<\/em>, which held that the laws Congress has enacted specifying Election Day for presidential and congressional elections permit states to count mailed ballots that arrive at local election offices after Election Day as long as they were postmarked by that date. Again, the liberals joined Roberts and Barrett for a five-justice majority opinion \u2013 this time written by Barrett \u2013 and the four other justices dissented. Those four would have forced states to change decades-old practices regarding the receipt of mailed ballots, despite Congress having updated the applicable federal laws based on an acceptance of those practices.<\/p>\n

Roberts and Barrett merit commendation in these two cases because they acted with judicial integrity, doing what judges are supposed to do: endeavoring to determine as best as they can what the law objectively requires of them regardless of their personal preferences. It\u2019s not just that they agreed with the liberals that\u2019s praiseworthy; that is not at all the point. Sometimes what the law objectively requires accords with the policy preferences of conservatives, and then it is liberal judges who are obligated to follow the law despite their personal opposition to it. In these two cases, however, it so happened that the law corresponded to what liberals wanted, and consequently it became the duty of conservative judges to accept the dictates of the liberal law. (Arguably, a case from this past term in which the three liberal justices should have recognized that the law contradicted their policy preferences was Mullin v. Al Otro Lado<\/em>, which involved a statute that explicitly applies to an asylum seeker who \u201carrives in\u201d the U.S. but which the liberal justices would have extended to asylum seekers appearing at U.S. borders but blocked from entry into the U.S. As much as sensible and humane asylum policy may have favored the liberal dissenters in that case \u2013 the opposite position incentivizes illegal immigration \u2013 the literal text of the law favored the conservative majority, who required Congress to amend the statute if it wants to liberalize the nation\u2019s asylum policy.)<\/p>\n

In Barbara<\/em>, Roberts masterfully explains why the only possible conclusion is that the first sentence of the 14th Amendment grants citizenship to children born on U.S. soil even if their parents are here temporarily or unlawfully. He starts with English law before the American Revolution, which made anyone born in the British Empire subjects of the British monarch. He shows that after independence all the states retained the idea that citizenship depends on location of birth, converting this status from duty to the Crown to the right of membership in the self-governing polity. \u201cCitizenship, then as now,\u201d Roberts writes, \u201cwas the right to have rights\u2014to freely participate in our political community.\u201d Slavery in the South proved the sole exception to this rule, and Dred Scott<\/em> constitutionalized the South\u2019s position on this issue for the entire nation. Thus, the 14th Amendment\u2019s first sentence \u2013 \u201cAll persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the state wherein they reside\u201d \u2013 must be understood as repudiating Dred Scott<\/em> and reestablishing the principle that anyone born on U.S. soil to parents subject to U.S. law (and thus not foreign diplomats or the like) is automatically a U.S. citizen.<\/p>\n

The four dissenters abandon this straightforward and well-settled understanding of birthright citizenship conferred by the 14th Amendment, arguing instead that the constitutional right of citizenship by being born in the U.S. is limited to the children of parents \u201cdomiciled\u201d in the U.S. But as Roberts points out, the text of the 14th Amendment doesn\u2019t use the term \u201cdomicile\u201d when it easily could have, and the more natural meaning of the phrase \u201csubject to the jurisdiction thereof\u201d is simply the limited qualification that the laws of the United States are enforceable against the new-born child\u2019s parents, which they are unless the child\u2019s parents are foreign diplomats or foreign soldiers (and accompanying consorts) who have managed to take military control over a portion of U.S. territory \u2013 or, in an exception , are members of a Native American tribe living on tribal lands subject to the tribe\u2019s jurisdiction as a foreign (albeit dependent) nation. The effort to read into the text of the Constitution the term \u201cdomicile,\u201d which isn\u2019t there, is an example of judges improperly distorting the words of the Constitution to fit their own personal policy preferences. As Roberts proclaims, \u201c[t]here is scant evidence for this dramatically revisionist view.\u201d<\/p>\n

To be clear, I don\u2019t wish to dispute the dissenters\u2019 view of immigration policy. It is reasonable to believe that citizenship shouldn\u2019t be conferred automatically in situations of so-called \u201cbirth tourism\u201d \u2013 or to children of immigrants in this country unlawfully. But that policy position requires a constitutional amendment, just as does the desire to replace the Electoral College with a national popular vote for president. Sometimes the text of the Constitution stands in the way of what might be a sensible policy position.<\/p>\n

The same point applies to Watson<\/em>, although that case involved statutory rather than constitutional interpretation. The Republican Party there argued the congressional specification of Election Day for federal offices as \u201cthe Tuesday next after the first Monday in November\u201c requires that mailed ballots arrive at local election offices by that date and thus do not permit states to count ballots arriving later as long as they are postmarked by that date. In rejecting this argument, Barrett carefully canvassed the history of congressional legislation concerning the specification of Election Day and its relation to absentee voting. What has to happen by Election Day, according to the applicable federal statutes, is that the voters must make their choice by marking and transmitting their ballots. She observed that the federal Uniformed and Overseas Citizens Absentee Voting Act, enacted in 1986, permitted states to set the deadline for when cast absentee ballots must be returned to local election officials. Indeed, UOCAVA explicitly states that military ballots must be delivered to \u201cappropriate election officials\u201d \u201cnot later than the date by which an absentee ballot must be received in order to be counted in the election\u201d \u2013 a provision which, as Barrett noted, \u201cwould make little sense\u201d if Congress had \u201cestablished a nationwide ballot-receipt deadline\u201d of Election Day.<\/p>\n

Barrett also astutely explained that the Electoral Count Reform Act, adopted in 2022 after the insurrection at the Capitol during the counting of electoral votes in the 2020 presidential election, redefines Election Day to permit, in emergency circumstances, the extension of voting to one or more extra days. This change was made with Congress knowing that many states permitted mailed ballots to be received after Election Day as long as they were cast by that date. Thus, Barrett concluded that ECRA confirmed the longstanding view that \u201c[t]he electorate\u2019s choice is made when voting is complete, not when ballots are received.\u201d<\/p>\n

Barrett convincingly demolishes the dissent\u2019s efforts to evade the operative provisions of federal law. The dissent tries to rely on 19th century history, observing in particular that when absentee voting was introduced during the Civil War military ballots were required to arrive at a soldier\u2019s home precinct by Election Day even though that might be logistically difficult. If states could have been more lenient with the deadline for receiving a soldier\u2019s absentee ballot, they would have \u2013 Justice Samuel Alito argued for the four dissenters \u2013 and so the fact that they were strict with this deadline indicates their belief that federal law specifying Election Day prevented their leniency. Even assuming the accuracy of this Civil War point, Barrett demonstrates its irrelevance because Congress repeatedly amended its Election Day statutes in the two subsequent centuries, after states had already liberalized their rules regarding the receipt of absentee ballots. And the four dissenters simply had no answer for what UOCAVA or ECRA provide.<\/p>\n

Ultimately, all the dissent has going for it is policy. Indeed, it is a very strong policy argument: it would be much better for voter confidence in the result of elections if all ballots could be counted quickly after the polls close on Election Day. Just recently, we saw how disconcerting it was that California took so long to count ballots in its gubernatorial primary and the Los Angeles mayoral race. But that compelling policy point is utterly irrelevant to the judicial obligation to enforce the law. \u201cAs we have said time and again,\u201d Barrett chided the four dissenters, \u201cpolicy arguments are properly directed to legislatures, not courts.\u201d<\/p>\n

Read more A history of justices testifying before Congress<\/a><\/p>\n

Given the judicial integrity that Roberts and Barrett displayed in Barbara<\/em> and Watson<\/em>, it is disconcerting that they deviated from this rectitude in Louisiana v. Callais<\/em>, the case that obliterated the protection that the Voting Rights Act was supposed to provide against unequal electoral power for minority voters. In Callais<\/em>, Roberts and Barrett joined their four more conservative colleagues over the dissent of the three liberals. The majority opinion in Callais<\/em>, written by Alito, was based solely on policy \u2013 just as were Alito\u2019s dissents in Barbara<\/em> and Watson<\/em> \u2013 and had nothing to do with the operative constitutional text.<\/p>\n

Roberts and Barrett undoubtedly thought that they were doing law rather than policy in Callais<\/em>. But they were not. The basis for the court\u2019s decision in Callais<\/em> was the court\u2019s insistence on enforcing its conception of a \u201ccolorblind Constitution\u201d \u2013 as the court confirmed when describing Callais<\/em> in its follow-up ruling in the Alabama case Allen v. Milligan<\/em>. The concept of a colorblind Constitution also motivated the court\u2019s decision in Students for Fair Admissions v. Harvard<\/em>, the 2023 case that invalidated affirmative action by universities. The Callais<\/em> majority repeatedly cited SFFA<\/em> for the proposition that the Constitution forbids \u201crace to play any part in government decisionmaking.\u201d Whatever validity this idea of constitutional colorblindness has in the context of college admissions, however, there is no warrant for it whatsoever in the context of legislative districting.<\/p>\n

The constitutional text that the court relied upon in SFFA<\/em> to ban affirmative action is the equal protection clause of the 14th Amendment, which provides that \u201c[n]o state shall \u2026 deny any person within its jurisdiction equal protection of the laws.\u201d It is debatable whether the original public meaning of these words disallows universities to consider race as a positive factor when making admissions decisions. But there can be no debate that the original public meaning of these words imposes no constraints on the legislative consideration of race in the context of laws concerning elections.<\/p>\n

To understand this, let\u2019s review some points I made in a previous SCOTUSblog column. We know that the original public meaning of the equal protection clause had nothing to do with elections because it guarantees \u201cequal protection of the laws\u201d to every \u201cperson<\/em>\u201d \u2013 male or female \u2013 and there was absolutely no understanding at the time that these words guaranteed equal voting rights to women. The 19th Amendment, a half-century later, was necessary for that, as everyone understood.<\/p>\n

If any further proof were necessary that the equal protection clause did not prevent states from considering race when enacting laws on voting and elections, just look at section 2 of the same 14th Amendment that contains the equal protection clause. That section specifically permits states to deny equal voting rights on the basis of race, the only consequence being that states will lose seats in the federal House of Representatives if they choose to do so. It was well understood by everyone at the time that nothing in the 14th Amendment barred states from discriminating on the basis of race with respect to voting.<\/p>\n

The 15th Amendment, on the other hand, states that \u201c[t]he right of citizens of the United States to vote shall not be denied or abridged by the United States or by any state on account of race.\u201d So does the 15th Amendment then guarantee that the government must be colorblind when considering any law concerning elections? No. Its words do not say that the government must not<\/em> make race a factor when it decides where to set the boundaries of legislative districts. It is indeed arguable that these words do not have any application to redistricting at all and instead apply only to regulation of casting and counting votes. But even if the original public meaning of these words does<\/em> constrain a state\u2019s districting decision, it does so only to the extent that those decisions \u201cabridge\u201d the right to vote by causing an inequality in the right to vote \u201con account of race.\u201d In other words, the only way a state\u2019s redistricting could cause a 15th Amendment violation would be if that redistricting resulted in unequal voting power because of race.<\/p>\n

But what the court\u2019s decision in Callais<\/em> does is to eviscerate the Voting Rights Act because of an insistence that there can be no consideration of race in redistricting even when that consideration is to assure equality of electoral opportunity for voters of different races. That insistence, it seems to me, comes solely from the policy preferences of the justices in the Callais<\/em> majority, including Roberts and Barrett. It in no way comes from the text of the 14th or 15th Amendments, or the original public meaning of those texts.<\/p>\n

Thus, the sad truth is that in Callais <\/em>Roberts and Barrett failed to abide by the standard of judicial integrity they upheld in Barbara<\/em> and Watson<\/em>. They let their personal policy preferences blind them to what the law required in Callais<\/em>.<\/p>\n

This mistake is no small matter: it denies Congress the power to legislate electoral equality for all voters regardless of race, a power Congress was originally meant to have with the adoption of the 15th Amendment. The tragedy of Callais<\/em> is not merely that Roberts and Barrett, along with the rest of the majority, substituted their policy preferences for what the Constitution \u2013 specifically, the 15th Amendment \u2013 requires; instead, the tragedy is that their policy preferences caused them to contradict the very purpose of the 15th Amendment and its empowerment of Congress to achieve that purpose and rectify racial injustice in voting laws.<\/p>\n

So, while I applaud Roberts and Barrett for what they did as judges of integrity in Barbara<\/em> and Watson<\/em>, I cannot overlook their opposite behavior in Callais<\/em>.<\/p>\n

Read more The Supreme Court and the opinion-assignment guessing game<\/a><\/p>\n<\/div>\n","protected":false},"excerpt":{"rendered":"

Chief Justice John Roberts and Justice Amy Coney Barrett deserve high praise for the pivotal role they played at the end of the just-concluded term in two key cases. Read more The biggest Supreme Court surprises this term One is Trump v. 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