Supreme Court Watch: Arizona v. United States

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Fam­ily Feud

On April 29, 2010, Ari­zona Gov­er­nor Jan Brewer signed into law SB 1070, which gave local author­i­ties sweep­ing pow­ers to detain sus­pected ille­gal immigrants.

The legal issue at ques­tion is taken directly from Arti­cle VI,  Para­graph 2 of the Con­sti­tu­tion, com­monly called the Supremacy Clause:

This Con­sti­tu­tion, and the Laws of the United States which shall be made in Pur­suance thereof; and all Treaties made, or which shall be made, under the Author­ity of the United States, shall be the supreme Law of the Land; and the Judges in every State shall be bound thereby, any Thing in the Con­sti­tu­tion or Laws of any state to the Con­trary notwithstanding.

The prin­ci­ple which arises out of this para­graph is called preëmp­tion. Preëmp­tion can be express (i.e. explicit, stated clearly) or implied. The basic ques­tion for the Court, in oral argu­ments today, will be: does SB 1070 run afoul of the Supremacy Clause?

Arti­cle I Sec­tion 8 of the United States Con­sti­tu­tion gives Con­gress the author­ity to reg­u­late nat­u­ral­iza­tion, that is, explic­itly preëmpts state law on the matter:

The Con­gress shall have Power To … estab­lish an uni­form Rule of Naturalization …

It’s not a huge cog­ni­tive leap to imag­ine that nat­u­ral­iza­tion rules and immi­gra­tion poli­cies are in the same realm.

Ari­zona (iron­i­cally then led by Gov­er­nor Janet Napoli­tano who is now the Sec­re­tary of Home­land Secu­rity with author­ity over immi­gra­tion pol­icy) declared an emer­gency sur­round­ing immi­gra­tion in 2005. In a dou­ble irony, a report today by the Pew His­panic Cen­ter says that net immi­gra­tion into the United States from Mex­ico has been near-​​zero in the 2005 to 2010 period. That is, 1.4 mil­lion Mex­i­cans immi­grated to the U.S. dur­ing that period, while 1.4 mil­lion Mex­i­cans emi­grated back to Mex­ico dur­ing the same period. This is pre­sum­ably due to the Great Reces­sion of 2008. Is the tim­ing of this report a coin­ci­dence, on the eve of oral argu­ments before the Court? It’s hard to believe it could be.

Gold Hat: “We are Fed­erales… you know, the mounted police.” Dobbs: “If you’re the police, where are your badges?”

There are four dis­puted parts to SB 1070:

  1. Law enforce­ment is required to deter­mine an individual’s immi­gra­tion sta­tus upon any con­tact, or if they even sus­pect some­one is an ille­gal immi­grant (see #4 below). [This is sec­tion 2b of the law.]
  2. It is a vio­la­tion of Ari­zona state law to fail to reg­is­ter as an alien. [Sec­tion 3]
  3. Ille­gal aliens are not allowed to find work under Ari­zona law. [Sec­tion 5c]
  4. Ari­zona police have the power to make war­rant­less arrests of those sus­pected to be in vio­la­tion of Fed­eral immi­gra­tion law. [Sec­tion 6]

A par­tially divided Ninth Cir­cuit Court has ruled that these four pro­vi­sions of SB 1070 fall under the prin­ci­ple of preëmp­tion and are there­fore unconstitutional.

Under long-​​standing pol­icy, Con­gress allows the states to coöper­ate with the Fed­eral gov­ern­ment to enforce Fed­eral immi­gra­tion laws. Bill author Rus­sell Pearce (who has since been recalled by vot­ers) was among those spew­ing par­ti­san rhetoric and thumb­ing their noses at the Fed­erales, claim­ing they don’ need no stinkin’ badges.

This ought to be a no-​​brainer for the courts. I hope the appeals court allows our state to enforce the rule of law because the Obama admin­is­tra­tion doesn’t seem to care one whit for the safety of the cit­i­zens of Ari­zona. SB 1070 sim­ply reflects fed­eral immi­gra­tion law. This Obama team doesn’t want immi­gra­tion laws enforced — but that doesn’t mean that Ari­zona can’t take com­mon sense steps to pro­tect its own cit­i­zens. This is the first time in the his­tory of this Repub­lic, that a sit­ting Pres­i­dent has sided with a for­eign gov­ern­ment against our cit­i­zens and in fact sued them to pre­vent them from enforc­ing the laws of the land.

Now coun­sel for Ari­zona will argue before the Court that Ari­zona leg­is­la­tors only intended to help out the United States, in the required spirit of coöper­a­tion evi­dent in the above quote.

Over at SCO­TUS­blog, Stephen Wer­miel writes:

Coöper­a­tion did not seem to be Arizona’s main moti­va­tion in pass­ing the law. When Gov­er­nor Jan Brewer signed the leg­is­la­tion, known as S.B. 1070, in April 2010, she described it as “another tool for our state to use as we work to solve a cri­sis we did not cre­ate and the fed­eral gov­ern­ment has refused to fix.” Alabama, which recently passed a more restric­tive immi­gra­tion law, has defended its action in lower fed­eral court pro­ceed­ings on the basis of a need to stem the tide of unlaw­ful aliens. In seek­ing Supreme Court review, how­ever, Ari­zona now argues that its law is an effort to coöper­ate with fed­eral enforcement.

Gabriel Chin, a pro­fes­sor of immi­gra­tion law, firmly believes that SB 1070 will be struck down by the Supreme Court.

Every lower court to look at these types of statutes in Alabama, South Car­olina, Utah and Ari­zona has said they’re uncon­sti­tu­tional. As a sort of plain vanilla con­sti­tu­tional analy­sis ques­tion, if you look at the old cases, if you look at the statute, it’s pretty clear that Con­gress is in charge here. The fed­eral gov­ern­ment is in charge here.

…

These whole prob­lems came up before. They came up in the 1870s in Cal­i­for­nia, when Cal­i­for­nia wanted to drive out the Chi­nese. And the basic law was estab­lished by the U.S. Supreme Court and by Con­gress, then. And the idea is that these laws should be estab­lished and car­ried out by Congress.

Here’s what the Supreme Court said in 1876. The respon­si­bil­ity for the char­ac­ter of those reg­u­la­tions and for the man­ner of their exe­cu­tion belongs solely to the national gov­ern­ment. If it be oth­er­wise, a sin­gle state can, at her plea­sure, embroil us in dis­as­trous quar­rels with other nations.

Chin is argu­ing, as other experts have, for the doc­trine of express preëmp­tion in this case. Despite the heated argu­ments on this issue, it appears unlikely that the Supreme Court will find any Con­sti­tu­tional grounds to sup­port Ari­zona SB 1070.

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  1. I real­ize this isn’t part of the case, but I’m par­tic­u­larly trou­bled by the word­ing in 1070 that allows offi­cers to be sued for inad­e­quately enforc­ing that law. They are, then, in the posi­tion of being liable for not arrest­ing some­one, and simul­ta­ne­ously liable for arrest­ing that same some­one, sim­ply because the offi­cer is forced to make a deter­mi­na­tion based on insuf­fi­cient infor­ma­tion. It’s a nee­dle they shouldn’t have to thread.

    In any case, I’m curi­ous to see how Scalia han­dles this case. The con­ser­v­a­tive Ten­ther side of him surely wants to side with Ari­zona. But surely he rec­og­nizes that we can’t have 51 dif­fer­ent for­eign poli­cies. How will he thread that needle?

  2.  
    Any­one know how many states Bush sued in his 8 years? Lib­er­als cer­tainly are going after the states.

  3. But surely he rec­og­nizes that we can’t have 51 dif­fer­ent for­eign policies.

    Par­ti­san ide­o­logues are uncon­cerned with prac­ti­cal­ity or real­ity. Their con­cern is with mak­ing The Other Guy look bad.

     

  4. But surely he rec­og­nizes that we can’t have 51 dif­fer­ent for­eign poli­cies. How will he thread that nee­dle?
     
    Seems very easy. If a state appre­hends a terrorist…are the deemed to “have their own ter­ror pol­icy”? Not sure how “coör­di­na­tion with the Feds” turns into “over­rid­ing the Feds”. It hon­estly seems like a triv­ial case—should be a slam dunk for AZ.

  5. FYI on the same sub­ject:  In Sep­tem­ber 2007, the Bush admin­is­tra­tion sued the state of Illi­nois, seek­ing to have an Illi­nois immi­gra­tion statute declared uncon­sti­tu­tional under the Supremacy Clause of the U.S. Constitution.

    rgbact, use the Google if you want an exact count and let us know.

  7. Well, now that the argu­ing is over, I now under­stand that Scalia has no inter­est in thread­ing the nee­dle. He actively sup­ports hav­ing 51 for­eign poli­cies. For­tu­nately, he’s alone among the nine.

  8. rgbact,

    If a state appre­hends a terrorist…are the deemed to “have their own ter­ror policy”?

    No. But if a state passes a law requir­ing appre­hen­sion of ter­ror­ists, then they are.

    Here’s why it’s dif­fer­ent. Let’s assume for the sake of argu­ment that Arizona’s law pre­cisely mir­rors fed­eral law. What hap­pens when fed­eral law changes? The Ari­zona law then is no longer in sync with the fed­eral law. And there’s no pro­vi­sion for 1070 to auto­mat­i­cally change to remain in sync with fed­eral law.

  9. Why? Because he didn’t want Illi­nois to preëmpt fed­eral law on immi­gra­tion. Hmmm…
     
    Looks like IL was ban­ning the fed­eral sys­tem. My under­stand­ing is that AZ is just help­ing enforce the fed­eral sys­tem. That seems like a huge difference,

  10. rgbact,

    How about if a gang of rab­ble rousers decides to enforce immi­gra­tion pol­icy on its own? Is it okay to assem­ble a vig­i­lante mob posse? Since states don’t have the legal author­ity to enforce fed­eral law with­out the per­mis­sion of Con­gress, how does Arizona’s action dif­fer from that of an anar­chist mob? And why shouldn’t the mem­bers of the Ari­zona state leg­is­la­ture be thrown in fed­eral prison?

     

  11. @Michael
     
    The pos­si­bil­ity that offi­cers could be sued for inad­e­quate enforce­ment also trou­bles me, because who gets to deter­mine what “ade­quate” enforce­ment is?  How are they going to decide who is a “likely” ille­gal immi­grant?  By looks?  By clothes? By lan­guage?  Will the offi­cer be sued if he doesn’t stop every Hispanic-​​looking per­son that he meets?  What about all of the ille­gal Cana­di­ans?  How could the offi­cer ade­quately enforce the law if he doesn’t stop every sin­gle per­son? Or does he only have to demand papers of a Cau­casian if they say “aboot” or “eh”?  The AZ statute effec­tively requires all Amer­i­cans vis­it­ing or liv­ing in AZ to carry papers prov­ing their cit­i­zen­ship or risk being sub­jected to detain­ment.  And that’s about as un–Amer­i­can as any­thing I can imag­ine.
     
    Offi­cer:  “Please show doc­u­men­ta­tion that you are legit­i­mately here in this coun­try.“
    Cit­i­zen: “What?“
    Offi­cer: “I need to see your papers.“
    Cit­i­zen: “What papers? I’m an Amer­i­can.“
    Offi­cer: “Prove it.“
    Cit­i­zen: “Prove it?  This is a free coun­try. As an Amer­i­can, I don’t have to prove that.“
    Offi­cer: “If you can’t prove it then I have to arrest you and detain you until you pro­vide suf­fi­cient doc­u­men­ta­tion estab­lish­ing your right to res­i­dency.  If you can’t prove that you belong here, then we’ll deport you to the coun­try of our choice.”

  12. mclever,
    It does kind of come down to that. If you’re a cit­i­zen and speak with a for­eign accent, and you’d bet­ter carry your cit­i­zen­ship papers with you at all times.

    BTW, I was once asked by INS if I was a US cit­i­zen. I looked at him like he was crazy before I responded. I can’t be in any for­eign coun­try with­out being obvi­ously Amer­i­can, no mat­ter how hard I try to blend in. But the fact is, if the INS guy had demanded proof of my cit­i­zen­ship, I would have been out of luck. I had none.

    Should this law be upheld, any legal His­panic from Cal­i­for­nia must avoid being in Ari­zona at all costs, unless that per­son is also car­ry­ing a birth cer­tifi­cate, cit­i­zen­ship cer­tifi­cate, or pass­port. A Cal­i­for­nia driver’s license is not accept­able as proof of cit­i­zen­ship in Arizona.

  13. Michael,
    Funny that you’d get ques­tioned by INS.  I’ve been mis­taken for both British and Ger­man while trav­el­ing abroad, of course nei­ther while I was actu­ally in Eng­land or Ger­many. Out­side the USA, I’m pretty obvi­ously for­eign, but appar­ently I don’t always give off a scary Amer­i­can vibe.  Here in the USA, I was once asked if I was Cana­dian, but not by any­one in an offi­cial capac­ity.  Kinda funny, eh?
     
    The point remains that US cit­i­zens aren’t sup­posed to have to carry or pro­vide any proof of their cit­i­zen­ship or res­i­dency while in the United States. That’s the whole point of this being a free coun­try.  Frankly, I’m shocked that any­one who would con­sider them­selves mar­gin­ally Lib­er­tar­ian (as many con­ser­v­a­tives do) would see it any dif­fer­ently.   Or, maybe it’s only because they can’t imag­ine them­selves ever being stopped, and it’s all OK as long as it hap­pens to those people.

  14.  
    Looks like  another rough day in court for the Obama team.
     
    From NBC:
    Based on com­ments dur­ing Wednesday’s oral argu­ments on the case, even some of the court’s lib­eral jus­tices seemed to find no strong objec­tion to the most con­tro­ver­sial part of the law, which requires local police to check on the immi­gra­tion sta­tus of any­one they detain or arrest.
     

  15. rgbact posted an NBC article:

    seemed to find no strong objec­tion to the most con­tro­ver­sial part of the law, which requires local police to check on the immi­gra­tion sta­tus of any­one they detain or arrest.

    I dis­agree that this pro­vi­sion (sec­tion 2b) is the most con­tro­ver­sial part of the law. Not even the most ardent civil lib­er­tar­i­ans, in my expe­ri­ence, have a prob­lem with the police run­ning “wants and war­rants” on you if you are legit­i­mately arrested.

    If you look at the above dis­cus­sion, what scares peo­ple the most is sec­tion 6, which pro­vides — demands — war­rant­less arrest of any­one sus­pected of being too brown.

  16. I would trust Lyle Denniston’s SCO­TUS­blog analy­sis of the case more than MSNBC’s. This is a much more nuanced and accu­rate view, I think.

    Assum­ing that the Court does allow most, if not all, of S.B. 1070′s four sec­tions to go into effect, that still would not amount to final con­sti­tu­tional clear­ance for any of the sec­tions.  The case reached the Jus­tices in a pre­lim­i­nary state, and there will be ongo­ing chal­lenges in lower courts when the case is returned to them.   More­over, there are chal­lenges to some of those pro­vi­sions that the Court did not con­sider on Wednes­day, because they are not part of the fed­eral government’s legal assault on the Ari­zona statute.

    The most impor­tant of those remain­ing chal­lenges is the claim that at least two of the four sec­tions give police author­ity to arrest and detain peo­ple just because they look like for­eign­ers — in a phrase, “racial pro­fil­ing.”  While some of the amici in this case did raise that in their briefs, the fed­eral gov­ern­ment has stu­diously avoided the claim.   And, the moment that Solic­i­tor Gen­eral Don­ald B. Ver­rilli, Jr., took his place at the lectern to make the U.S. chal­lenge, Chief Jus­tice Roberts sought to make sure that he did not talk about “racial profiling.”

    Roberts said: “Before you get into what the case is about, I’d like to clear up at the out­set what it’s not about.  No part of your argu­ment has to do with racial or eth­nic pro­fil­ing, does it?  I saw none of that in your brief.”  Ver­rilli said that was cor­rect.  But the Chief Jus­tice wanted to be sure: “Okay.  So this is not a case about eth­nic pro­fil­ing.”  The Solic­i­tor Gen­eral answered: “We’re not mak­ing any alle­ga­tion about racial or eth­nic pro­fil­ing in this case.”

    Although no observer could be sure what moti­vated Roberts to make that point, he was either try­ing to keep that ques­tion out of the case because it would remain an issue in lower courts, or else he was seek­ing to head off crit­i­cism that, if the Court did allow Ari­zona to enforce S.B. 1070, the Court was not endors­ing racial or eth­nic profiling.

  17. I would also note that MSNBC has mod­i­fied the sec­tion rgbact quotes above. The new lede is much more nuanced and accurate:

    The U.S. Supreme Court indi­cated Wednes­day it appears ready to uphold one of the most con­tro­ver­sial parts of Arizona’s immi­gra­tion law: a require­ment that police offi­cers check the immi­gra­tion sta­tus of peo­ple they think are in the coun­try illegally.

    Also note that with for­mer Solic­i­tor Gen­eral Kagan recused, and with the Ninth Cir­cuit rul­ing against Ari­zona, that Ari­zona needs a 5–3 vote to prevail.

  18. Good points, Monotreme.
     
    It’s impor­tant to remem­ber that the SC deci­sion on the ques­tion cur­rently before it won’t answer for all time whether the AZ law is Con­sti­tu­tional or not, because they’re only con­sid­er­ing whether it’s step­ping on Fed­eral toes by cre­at­ing a sep­a­rate or inde­pen­dent immi­gra­tion pol­icy.  The ques­tion is all about pre­emp­tion.
     
    So, if I under­stand the sit­u­a­tion, the Court could rule now that the AZ law doesn’t vio­late the pre­emp­tion clause, but later a US Cit­i­zen could bring suit for hav­ing been detained, and the law could be ruled un-​​Constitutional on those grounds, because the police can’t detain cit­i­zens with­out cause. Or a class-​​action suit could be brought by a group of brown-​​skinned cit­i­zens who all got stopped for no other appar­ent rea­son.  Or per­haps a police offi­cer sued for fail­ing to enforce it thor­oughly enough for some racist res­i­dent could appeal the suit up through the courts, etc.

  19. As is so often the case, this may be an instance of Solomonic baby-​​splitting. On one hand, peo­ple who are here ille­gally should be found and deported. On the other hand, find­ing and deport­ing those who are here ille­gally should not sub­ject a much larger pop­u­la­tion of legal res­i­dents to undue cur­tail­ment of daily activities.

    27% of Arizona’s res­i­dents are His­pan­ics who are legal res­i­dents. More than one in four. If you add in the Native Amer­i­can pop­u­la­tion (who is to many indis­tin­guish­able from His­panic), you get an addi­tional 6%. This means that one in three legal Ari­zo­nans “look illegal”.

    The like­li­hood of false pos­i­tives is huge in that environment.

    What­ever sys­tem we develop to find and deport ille­gal res­i­dents, it shouldn’t be crafted in such a man­ner as to sub­ject a third of the legal pop­u­la­tion to ran­dom, lengthy, unwar­ranted incar­cer­a­tion. But that’s what 1070 nec­es­sar­ily does.

  20. Ari­zona, New Mex­ico, and Col­orado may be in play in the Pres­i­den­tial elec­tion in Novem­ber, thanks to AZ 1070. Florida and Vir­ginia are increas­ingly winnable for Pres­i­dent Obama. It’s a gift to the Democrats.

    Rom­ney can­not dis­tance him­self from the desire to side with big­ots against His­pan­ics and Lati­nos. The ads write them­selves — and might not need ever to be aired.

     

  21. The guy who co-​​authored AZ 1070 today admit­ted the pur­pose of the law was to max­i­mize America’s white population.

     

    Learn about Rus­sel Pierce here.

     

    Let’s see Rom­ney walk that back.

  22. Ari­zona, New Mex­ico, and Col­orado may be in play in the Pres­i­den­tial elec­tion in Novem­ber, thanks to AZ 1070.
     
    If PPACA is over­turned and 1070 is upheld.…Obama can have those states

    I’m actu­ally more inter­ested in how this effects the down bal­lot races. Chuck Shumer has a plan to put this issue to a vote if 1070 is upheld, so we’ll see how sen­a­tors and can­di­dates in the toss-​​up states come down on this. If DC is right, all the Sen­ate Dems should be drool­ing at the chance to vote against 1070.
     

  23. It never ceases to amaze me when folks, most of whom can’t even name eight of the nine jus­tices, assume they know the deci­sion the SCOTUS will make based on the ques­tions asked dur­ing orals.
     
    It’s worse when they expound on the case in a man­ner that demon­strates that they don’t under­stand what is at issue in the case before the SCOTUS and the pos­si­ble out­comes that will be decided.
     
    Take FAA v Cooper. The SCOTUS decided in favor of the FAA. Does that mean the FAA has won the suit filed against it by Cooper?
     
    No. The SCOTUS decided ONLY the ques­tion of vio­la­tion of the Pri­vacy Act of  1974, as per­tain­ing. The law­suit has never even been heard! The SCOTUS case was over the Motions for Sum­mary Judge­ment filed with the judge at the begin­ning. That suit may now go for­ward, but Cooper can­not hide behind the Pri­vacy Act. From a prac­ti­cal stand­point, this may well make Cooper’s case moot. I’ve not read his orig­i­nal Com­plaint, and there well may be other mat­ters at issue such that may allow him to move for­ward, or he may filed an Amended Com­plaint. We’ll see.

  24. rgbact,
     

    If PPACA is over­turned and 1070 is upheld.…Obama can have those states

    Such is the rea­son­ing of many on the right on the prospects of the future of the GOP. And it is pure denial. Denial of the chang­ing demo­graph­ics in this coun­try. The brown­ing of America.

    Because it AIN’T just “those states”. It’s also Florida, North Car­olina and Vir­ginia. And that’s just in the short term! What hap­pens when those states, now we’re up to SIX, become reli­ably blue? Do you want to give away all THOSE elec­toral votes? Because, even when you give Ohio, Iowa, Penn­syl­va­nia and New Hamp­shire to the GOP, those six, added to the cur­rent leans Demo­c­ra­tic or bet­ter, adds up to 310 EV!

    And not count­ing those lat­ter three, if they all go red, the Democ­rats tak­ing only Ohio will put them over 270.

    Be very care­ful in what you ask for.

  26. Agreed, Max. I think every­one assumed that Toobin’s read of the Jus­tices’ ques­tions dur­ing orals on PPACA is some sort of spe­cial wis­dom. I think he’s going to end up with egg on his face.

    I don’t pre­sume to know how the Jus­tices will decide PPACA or Ari­zona or, for that mat­ter, FAA v Cooper. That’s what I think is fas­ci­nat­ing about writ­ing up these Supreme Court Watch pieces.

    I do think the his­tory of the Roberts Court is to decide on very nar­row tech­ni­cal grounds, and I think that the one thing we can get out of orals in this case is that Roberts clearly sig­naled the world and his col­leagues that it’s going to be a very very nar­row decision.

  27. What hap­pens when those states, now we’re up to SIX, become reli­ably blue
    Go reread my immi­gra­tion arti­cle from a few months back about the “brown­ing” myth.  Here’s a recent arti­cle that basi­cally backs up what I had writ­ten.
    http://​decoded​.nation​aljour​nal​.com/​2​0​1​2​/​0​4​/​r​e​t​h​i​n​k​i​n​g​-​t​h​e​-​h​i​s​p​a​n​i​c​-​v​o​t​e​.​php
    And heres the money shot
    “Indeed, a com­ple­men­tary Pew His­panic Cen­ter study, released last month, showed immi­grants becom­ing more Repub­li­can the longer they’ve been in this coun­try — a sim­i­lar nar­ra­tive to other first-​​generation eth­nic groups”

    Agreed, Max. I think every­one assumed that Toobin’s read of the Jus­tices’ ques­tions dur­ing orals on PPACA is some sort of spe­cial wis­dom.“
    I agree. That why I said I would give up states EV’s for the rul­ings. But I’m sur­prised peo­ple assume PPACA is dead because of some tough ques­tion­ing. I’d say 1070 will be hard to over­turn though. I’ll put PPACA at 50⁄50 and 1070 at 90%.
     

  28. rgbact,
     

    1070 at 90%.

    I don’t think that you under­stand that there are SEVERAL parts of 1070 at issue before the SCOTUS? (As is the case of PPACA) That their deci­sion will not be all or noth­ing? If not, please go back and look at the big­ger pic­ture.
     
    How do you call the var­i­ous PARTS of 1070 before the Court.
     

    Go reread my immi­gra­tion article 

    Yes, I read it back then. And noth­ing changes, IMHO. The real­ity of the past sev­eral pres­i­den­tial elec­tions and the His­panic vote tell a dif­fer­ent empir­i­cal tale. I’d rather go with the facts ver­sus a good theory.

  29. Max, in other words, rgbact is hoping’/prayin’ His­pan­ics don’t become the major­ity vot­ing block in Amer­ica any­time soon.

    Again, as older white folk con­tinue to pass on to teabag­ger heaven …

    So it shall be writ­ten, so it shall be done. Praise the Lord!

    Repub­li­cans = short term imag­i­nary gain vs. big polit­i­cal pic­ture as they can’t see the for­est for the trees because of inate bigotry/​prejudice. As per usual.