Appropos of our discussion . . .

. . . the Ninth Circuit just issued an opinion this morning holding that an Arizona law requiring that voters present proof of citizenship when registering to vote was preempted by federal immigration law. You can find the Ninth Circuit's opinion here, and you can find commentary here. The decision was 2-1. Judge Sandra Ikuta wrote the majority, and she was joined by former Justice Sandra Day O'Connor. Judge Alex Kozinski authored a lengthy dissent. (Interestingly, Judge Ikuta clerked for Judge Kozinski, and then for Justice O'Connor, in the 1980s.)