Many commentators, myself included, perceived a different headline to the Supreme Court’s rejection in Trump v. Barbara of Trump’s executive order in the birthright citizenship case. The real gobsmacking detail was not the court’s holding, which was broadly signaled in oral arguments, but the fact that four justices—Clarence Thomas, Neil Gorsuch, Samuel Alito, and Brett Kavanaugh—were prepared to uphold a radically counter-textual reading of the plain text of the Fourteenth Amendment to exclude