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BBC News
June 27, 2025
Samuel Bray, a Notre Dame Law School professor and expert on nationwide injunctions, said the ruling "has fundamentally reset the relationship between the federal courts and the executive branch".
NPR
June 27, 2025
"An injunction is an order by a court telling somebody to do something or not do something," explains Samuel Bray, a law professor at the University of Notre Dame. Usually injunctions protect the parties to the case. But a universal injunction "controls how the federal government acts toward anyone." He says universal injunctions are "a recent innovation" and their use has seen "a meteoric rise over the last 10 years" in tandem with an increase in executive orders issued by the administrations of presidents Barack Obama, Trump and Joe Biden.
Newsweek
June 27, 2025
Professor Samuel Bray, a nationwide injunctions expert at Notre Dame Law School, told Newsweek that there would likely be litigation now on two fronts—Firstly, the states that want broader injunctions against Trump's executive order, and secondly, a "surge of new class actions" against how the executive order will be enforced.
Bloomberg
June 27, 2025
President Joe Biden gained 57 openings, both current and future, between January 1 and June 1 of his first year in office, according to Derek Muller, a University of Notre Dame law professor who tracked the early pace of vacancies for recent presidencies using the US Courts’ archived data. George W. Bush had 30 during the same time frame, while 29 opened for Obama.
NBC News
June 27, 2025
Samuel Bray, a critic of nationwide injunctions at Notre Dame Law School whose work was cited in the ruling, said both the states and individual plaintiffs can still get broad injunctions against the birthright citizenship executive order, potentially even on a nationwide basis. "I don't expect the executive order will ever go into effect," he added.
Disclaimer: The opinions expressed in these articles do not necessarily reflect those of the University.
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