Jeremy Feigenbaum

Since the 14th Amendment, our country has never allowed American citizenship to vary based on the state in which someone resides. Because the post-Civil War nation wrote into our Constitution that citizens of the United States and of the states would be one and the same without variation across state lines.

Since the 14th Amendment, our country has never allowed American citizenship to vary based on the state in which someone resides. Because the post-Civil War nation wrote into our Constitution that citizens of the United States and of the states would be one and the same without variation across state lines.

Since the 14th Amendment, our country has never allowed American citizenship to vary based on the state in which someone resides. Because the post-Civil War nation wrote into our Constitution that citizens of the United States and of the states would be one and the same without variation across state lines.

Mr. Feigenbaum. Mr. Chief Justice, and may it please the court, this court should deny the emergency application because this injunction was properly designed to ensure that the states would get relief for our own Article III injuries, as we suffer significant pocketbook and sovereign harms from implementation of this executive order.

Mr. Feigenbaum. Mr. Chief Justice, and may it please the court, this court should deny the emergency application because this injunction was properly designed to ensure that the states would get relief for our own Article III injuries, as we suffer significant pocketbook and sovereign harms from implementation of this executive order.

The U.S. prefers alternative approaches for granting that relief. but its approach would require citizenship to vary based on the state in which you're born, or even turn on or off when someone crosses state lines, raising serious and unanswered administrability questions, not just for the federal government, but also for the states.

The U.S. prefers alternative approaches for granting that relief. but its approach would require citizenship to vary based on the state in which you're born, or even turn on or off when someone crosses state lines, raising serious and unanswered administrability questions, not just for the federal government, but also for the states.

The states who regularly come before this court as plaintiff and defendant alike agree that nationwide relief can be reserved for narrow circumstances.

The states who regularly come before this court as plaintiff and defendant alike agree that nationwide relief can be reserved for narrow circumstances.

And we have, in New Jersey, 6,000 babies born out of state every year.

And we have, in New Jersey, 6,000 babies born out of state every year.

They come into our state, they need benefits. We have to do citizenship verifications, which is a burden for us.

They come into our state, they need benefits. We have to do citizenship verifications, which is a burden for us.

And that comes to the United States as alternative, Justice Sotomayor, which is they say, OK, maybe their citizenship turns on when they enter New Jersey, maybe for some purposes, maybe for all purposes, depending on which sentence you're looking at.

And that comes to the United States as alternative, Justice Sotomayor, which is they say, OK, maybe their citizenship turns on when they enter New Jersey, maybe for some purposes, maybe for all purposes, depending on which sentence you're looking at.

It will undermine the administration of our benefits program. So individuals will move in. When they were born, they were treated as non-citizens. They didn't get Social Security numbers because they wouldn't have been eligible for the enumeration at birth program in their states. And they're going to arrive and they're going to seek benefits that we administer.

It will undermine the administration of our benefits program. So individuals will move in. When they were born, they were treated as non-citizens. They didn't get Social Security numbers because they wouldn't have been eligible for the enumeration at birth program in their states. And they're going to arrive and they're going to seek benefits that we administer.

But federal law requires that they have Social Security numbers for the administration of those benefits.

But federal law requires that they have Social Security numbers for the administration of those benefits.

So you're going to need to have Social Security numbers. They're going to arrive without them, even though they were, under this court's precedence, citizens who should have been in the enumeration at birth program who should have had Social Security numbers. And it's going to be a burden on us.

So you're going to need to have Social Security numbers. They're going to arrive without them, even though they were, under this court's precedence, citizens who should have been in the enumeration at birth program who should have had Social Security numbers. And it's going to be a burden on us.

This court could set supplemental briefing on the merits by an order tomorrow if it wished, specifically to say... Because you wouldn't have to deal with

This court could set supplemental briefing on the merits by an order tomorrow if it wished, specifically to say... Because you wouldn't have to deal with