Blue Brief 2025-2026

rule that appears to leave few uncertainties or openings for narrower application by the lower courts or the executive branch. Absent a (quite unlikely) constitutional amendment, it appears to firmly resolve the matter. Thus, attention in the executive branch and Congress

is likely to shift to enhanced enforcement targeted at reducing the number of births in the United States to parents who are not citizens or lawful permanent residents, and perhaps to situations in which citizenship might be lost by subsequent actions or circumstances.

Michael Ramsey

UNIVERSITY OF SAN DIEGO SCHOOL OF LAW | Faculty Review of 2025-2026 U.S. Supreme Court Term | Page 28