{"id":446,"date":"2026-07-28T13:41:40","date_gmt":"2026-07-28T13:41:40","guid":{"rendered":"https:\/\/americanservicereview.com\/?p=446"},"modified":"2026-07-28T13:41:40","modified_gmt":"2026-07-28T13:41:40","slug":"notable-concurring-opinions-from-this-term","status":"publish","type":"post","link":"https:\/\/americanservicereview.com\/?p=446","title":{"rendered":"Notable concurring opinions from this term"},"content":{"rendered":"
\n

Sometimes concurring opinions of justices add little to what is in the court\u2019s decision. Other times, however, they take a very different approach and urge a major change in the law. In my last column for SCOTUSblog, I wrote of Justice Clarence Thomas\u2019 astounding concurring opinion in Mullin v. Doe<\/em> in which he argued that the equal protection clause does not apply to the federal government and that Bolling v. Sharpe<\/em>, which held otherwise, was wrongly decided. There were several other particularly notable concurring opinions that would dramatically alter the law if followed.<\/p>\n

Read more The ongoing battle over TPS status<\/a><\/p>\n

Justice Kagan\u2019s concurring opinion in Chiles v. Salazar<\/em><\/strong><\/p>\n

In Chiles v. Salazar<\/em>, the court held that strict scrutiny \u2013 the most stringent standard of court review \u2013 should be applied to a Colorado law prohibiting conversion therapy for gay, lesbian, and transgender youth, and, as a result, such a ban wrongly discriminated against a counselor based on views she expressed in therapy. The court, in an opinion by Justice Neil Gorsuch, said that the law was a content-based restriction on speech in that the state was prohibiting expression trying to change, but not trying to affirm, a minor\u2019s sexual orientation or gender identity.<\/p>\n

Justice Elena Kagan wrote a concurring opinion, joined by Justice Sonia Sotomayor. She began her opinion by stating: \u201cI write only to note that if Colorado had instead enacted a content-based but viewpoint-neutral law, it would raise a different and more difficult question.\u201d<\/p>\n

Under current law, a content-based restriction on speech must meet strict scrutiny, and a law can be found to be content-based in either of two ways: a subject-matter restriction (in which it regulates speech based on a topic) or a viewpoint restriction (in which it regulates a particular view).<\/p>\n

A case from 1980, Carey v. Brown<\/em>, is illustrative. Chicago adopted an ordinance prohibiting all picketing in residential neighborhoods unless it was labor picketing connected to a place of employment. The Supreme Court held this regulation unconstitutional. The court explained that the law allowed speech if it was about the subject of labor, but not otherwise. The court said that whenever the government attempts to regulate speech in public places, it must be subject matter neutral unless the government meets strict scrutiny \u2013 that is, the regulation is necessary to achieve a compelling purpose.<\/p>\n

Similarly, in the 2000 case of United States v. Playboy Entertainment Group, Inc.<\/em>, the court found that a law that regulated only sexual speech was a subject matter restriction and had to meet strict scrutiny. A provision of the federal Cable Act prohibited \u201csignal bleed\u201d of sexual images; signal bleed occurs when people receive images from cable stations to which they do not subscribe. The law required that cable companies either completely eliminate signal bleed of sexual images or that sexual programming be shown exclusively during late-night hours. In finding the law unconstitutional, Justice Anthony Kennedy declared: \u201cThe speech in question is defined by its content; and the statute which seeks to restrict it is content based.\u201d He explained that the law \u201capplies only to channels primarily dedicated to \u2018sexually explicit adult programming or other programming that is indecent.\u2019 … It \u2018focuses only on the content of the speech and the direct impact that speech has on its listeners.\u2018 This is the essence of content-based regulation.\u201d<\/p>\n

In these and many other cases, the court found that subject matter restrictions on speech are content-based and must meet strict scrutiny. In Chiles v. Salazar<\/em>, Kagan says that she would not have used strict scrutiny if the Colorado law had been a subject-matter restriction instead of a viewpoint restriction. If only viewpoint restrictions, not subject-matter restrictions, must meet strict scrutiny, that would substantially lessen the Constitution\u2019s protection for speech.<\/p>\n

Gorsuch\u2019s concurring opinion in Chatrie v. United States<\/em><\/strong><\/p>\n

The issue in Chatrie v. United States<\/em> was whether police use of a geofence is a search for purposes of the Fourth Amendment. A geofence is where police obtain information about all of the cellular devices within a designated area at a specific time. The court in a 6-3 decision, with the majority opinion written by Kagan, concluded that this is a search because it infringes the \u201creasonable expectation of privacy\u201d that people possess in the location information generated by their cellular devices.<\/p>\n

Gorsuch wrote an opinion concurring in the judgment which, if followed, would greatly change the law. He sharply criticized the reasonable expectation of privacy test for determining what is a search. Since the court\u2019s decision in 1966\u2019s Katz v. United States<\/em>, the court has found that there is a search if there is a government infringement of one\u2019s reasonable expectation of privacy. In Chatrie<\/em>, Gorsuch wrote, \u201cIf Katz\u00a0<\/em>has become a familiar feature of our law, it seems to me no more persuasive for it. … It has no basis in the Constitution’s text or history. The Fourth Amendment’s protections do not depend on\u00a0\u2018the breach of some abstract \u201cexpectation of privacy\u201d whose contours are left to the judicial imagination.\u2019\u201d\u00a0<\/p>\n

Gorsuch would take a very different approach to determining whether there is a search. He would have found that there was a search in Chatrie <\/em>because the Fourth Amendment protects a person\u2019s \u201ceffects\u201d and the government obtaining location history is an intrusion into them. He explained that the \u201cword \u2018effects\u2019 was understood at the time of the Fourth Amendment’s adoption to embrace most any kind of personal property. As I see it, Mr. Chatrie\u2019s Location History data qualifies as his personal property.\u201d<\/p>\n

Read more Trump administration asks Supreme Court to clear the way for new mail-in voting restrictions<\/a><\/p>\n

If followed, Gorsuch\u2019s approach to the Fourth Amendment would reject 60 years of precedents for determining what is a search. This would lessen the protection of privacy. For example, police observing people through drones or cameras on utility poles would not be a search under the Gorsuch approach. But they certainly invade a reasonable expectation of privacy.<\/p>\n

Thomas\u2019 concurring opinion in Monsanto Co. v. Durnell<\/em><\/strong><\/p>\n

The issue in Monsanto Company v. Durnell<\/em> was whether a federal statute, the Federal Insecticide, Fungicide, and Rodenticide Act, preempts allowing liability under state tort law for the failure to include warning labels on a product. The case involved the weedkiller Roundup and whether a man who developed cancer, allegedly from its use, could sue the manufacturer for not including warning labels on the product. The Supreme Court, in a 7-2 decision with the majority opinion written by Justice Brett Kavanaugh, found that the federal statute expressly preempted (precluded) such state tort liability. Justice Ketanji Brown Jackson dissented, joined by Gorsuch (not a frequent pairing of justices).<\/p>\n

Thomas wrote a concurring opinion in which he made three arguments, each of which would be a dramatic change in the law. First, he said that \u201cthe Act likely exceeds Congress’s authority under the Commerce Clause. … This power allows Congress to regulate \u2018selling, buying, and bartering\u2019 across state lines. It does not allow Congress to regulate \u2018agriculture\u2019 or \u2018manufacturing,\u2019 activities entirely \u2018separate\u2019 from \u2018commerce.\u2019\u201d This was the view of the Supreme Court during the first third of the 20th century when the court struck down many federal laws as exceeding the scope of Congress\u2019 commerce power, but it has been emphatically rejected ever since. It would make countless federal laws unconstitutional.<\/p>\n

Second, Thomas said that the statute raised the issue of \u201cCongress\u2019s ability to delegate core legislative power to the EPA.\u201d Since 1935, not one federal law has been declared unconstitutional as an excessive delegation of legislative power. Changing this would put a myriad of federal laws in constitutional jeopardy.<\/p>\n

Third, Thomas said that \u201cthe Act raises questions about the extent to which federal agency action can preempt state law, a form of preemption taken for granted by the parties in this case.\u201d He argued that agency regulations should not have the ability to preempt state law, which also would be a dramatic change in the law.<\/p>\n

Justice Brett Kavanaugh\u2019s concurrence in Trump v. Barbara<\/em><\/strong><\/p>\n

One other concurring opinion that was surprising, though it did not advocate a change in the law, was Kavanaugh\u2019s concurrence in Trump v. Barbara.<\/em> Chief Justice John Roberts wrote a majority opinion declaring unconstitutional President Donald Trump\u2019s executive order limiting birthright citizenship. Kavanaugh would have found the executive order constitutional but would have struck it down on statutory grounds.<\/p>\n

In his discussion of the constitutional issue in Barbara<\/em>, Kavanaugh, who previously had embraced originalism, such as in his concurring opinion in New York State Rifle and Pistol Association v. Bruen<\/em> (which held that there is a Second Amendment right to carry concealed weapons outside the home), wrote in a way that seemingly adopts the perspective of a living Constitution. He stated: \u201cThe original constitutional principles do not change absent a constitutional amendment, but the relevant principles\u2014both the rules and exceptions alike\u2014must be faithfully applied not only to circumstances as they existed in 1787, 1791, and 1868, for example, but also to modern situations that were unknown or unanticipated by the Constitution’s Framers. … So too, the issue of temporary visitors who give birth in the United States presents a new and different circumstance than in 1868 given the significant changes in immigration laws and travel.\u201d As a result, Kavanaugh concluded that the Trump executive order limiting birthright citizenship was constitutional, though he would have invalidated it as violating a federal statute.<\/p>\n

Of course, the same could be said to justify restrictions on firearms, protection of reproductive autonomy, and limits on campaign spending. All deal with \u201cmodern situations that were unknown or unanticipated by the Constitution\u2019s Framers.\u201d Kavanaugh\u2019s words in Trump v. Barbara<\/em> thus seem quite difficult to reconcile with his professing to be an originalist.<\/p>\n

Read more Why the Supreme Court decided the wrong issue in the transgender athletes cases<\/a><\/p>\n<\/div>\n","protected":false},"excerpt":{"rendered":"

Sometimes concurring opinions of justices add little to what is in the court\u2019s decision. Other times, however, they take a very different approach and urge a major change in the law. In my last column for SCOTUSblog, I wrote of Justice Clarence Thomas\u2019 astounding concurring opinion in Mullin v. Doe in which he argued that […]<\/p>\n","protected":false},"author":1,"featured_media":41,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[11,15],"tags":[],"class_list":["post-446","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-commentary","category-courtly-observations"],"yoast_head":"\nNotable concurring opinions from this term - American Service Review<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/americanservicereview.com\/?p=446\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Notable concurring opinions from this term - American Service Review\" \/>\n<meta property=\"og:description\" content=\"Sometimes concurring opinions of justices add little to what is in the court\u2019s decision. 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