"[T]he majority warmly reaffirmed a constitutional doctrine, known as obstacle preemption, that will favor the federal government’s interests in a wide swath of future cases. It also strongly endorsed the primacy of the federal government in immigration control, in the face of a stunningly vitriolic dissent from Justice Scalia asserting the sovereign exclusion powers of the states. And it rejected a “mirror-image” theory propounded by SB 1070’s proponents that promised much future state legislative mischief." - David Martin, Reading Arizona, 98 Va. L. Rev. In Brief 41 (2012).
- David Martin