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In recent case in which eight Justices voted to grant a stay of a lower court injunction, and KBJ wrote another fiery dissent, Justice Sotomayor wrote a separate concuring opinion directed at KBJ and "explained it to her like she was a fifth grader, in very simple terms that apparently Justice Jackson to the end was unable to grasp."

"These injunctions—known as “universal injunctions”—likely exceed the equitable authority that Congress has granted to federal courts.... The applications do not raise—and thus we do not address—the question whether the Executive Order violates the Citizenship Clause or Nationality Act."