The Fourteenth Amendment lays out birthright citizenship in clear terms. Every subsequent legal challenge and all the scholarly work on the subject — until about a year ago — agreed on how to read it. Yet, the Supreme Court still managed to split on the question, with a 6-3 decision knocking down Donald Trump’s executive order purporting to overturn the key constitutional provision — that was more accurately 5-4, with Kavanaugh agreeing with the result on other grounds, but joining the dissent in erasing the Fourteenth Amendment. Or maybe it was 6-3 with an asterisk, because Neil Gorsuch went rogue, mostly agreeing with birthright citizenship in the only scenario the Trump administration really wanted to snuff out. Chief Justice Roberts also took his burning desire to be seen as the middle of the Court comically too far, authoring contradictory opinions back-to-back. And Sam Alito did not retire, despite reports. And in Biglaw, we continue to wonder where all the raises are.