July 2024 Newsletter

Foreword - Introduction to APA

Welcome Statement

On this Independence Day, the 248th birthday of our nation, we would like to welcome you to the first monthly newsletter of the St Andrews American Politics Association. In this critical moment in American history - a time of conflict, turbulence, and debate, we hope to further productive discussions concerning the future of our country. For too long, American politics have divided us among social and economic backgrounds, turning neighbor against neighbor, friend against friend. Our best hope for an American future is to open discussions with tolerance and dignity, to better understand each other and overcome the false divisiveness perpetuated by political campaigns and media. 

We have established this society as an open place for discussion and debate surrounding American politics and policy in St Andrews. We feel as if there are many students with an interest in American politics and foreign policy, but no cohesive space for this particular subject. We welcome anyone with an interest in American politics, regardless of party or nationality. Our only membership requirement is mutual respect and understanding, which we believe is critical to fostering productive conversation.

Throughout this upcoming academic year, we look forward to a range of events, including pub socials, bonfires, and academic talks. Concerning the 2024 election, we will be hosting debate and election night watch parties, as a casual way to keep up with politics back home. We want to offer a blend of events - casual and professional- to cultivate discussion and community. The APA offers a range of ways to develop and share your opinions, in our upcoming podcast and monthly newsletters. At this time, we are looking for new members and committee members. Keep an eye out on our socials for more information! We look forward to meeting you at freshers week and beyond.

Best,

APA Executive Committee

standrewsapa@gmail.com 

@americanpoliticsassociation

Upcoming Events

☆ Freshers Week Launch Party

☆ Weekly Discussion Nights 

☆ Election Watch Parties

☆ Professional Development Talks

Mission Statement

The American Politics Association (APA) aims to provide the St Andrews community with a platform for open and nonpartisan conversation surrounding U.S. politics. 

With frequent discussions, podcasts, newsletters, and more, the APA strives to promote awareness of the changing political environment and recent developments. We also seek to support students who are interested in a career in U.S. politics and foster a space for networking. 

We encourage people of all backgrounds and subject areas to join us on our mission to increase engagement and awareness surrounding U.S politics in the St Andrews community and beyond. 

Election 2024 

Zachary Mandosa

Current Polling

As of July 1st, polling for the Presidential Election remains extremely close. Project 538, which compiles nation-wide polls, currently has candidate Donald Trump leading in polls by +1.7%. Notably, Trump is leading in all 7 key swing states, including North Carolina (+7.3%), Georgia (+6.3%), Arizona (+4.8%), Nevada (+3.8%), Pennsylvania (+2.0%), Michigan (+1.8%), and Wisconsin (+0.8%). In the 2020 election, at this point in the campaign, Biden led by a significant amount in all 7 of these states. To have no leads in any top swing state, and to be trailing nationally, is worrying for the Biden campaign. The race is too tight to make any judgments on, but if one thing is for certain, it’s that both candidates have a significant amount of work left to do to sway voters one way or another.

Debate Structure

Both the Biden and Trump campaigns agreed to move the location of the presidential debates to a television studio from a college campus. Both candidates agreed to have their microphones muted when the other candidate was speaking, there was no live studio audience, and candidates were restricted from consulting with their teams during commercial breaks. Each candidate was given 2 minutes for opening statements and given 2 minutes to answer each question and 1 minute for rebuttal. One consistent criticism of CNN’s format is that the moderators chose not to push back when misinformation was spread, allowing misinformation to run rampant. 

Post Debate Analysis

The performance of both candidates Thursday night was far from optimal. If people who listened to the radio in 1960 thought Richard Nixon won the presidential debate, people reading the transcript of the 2024 presidential debate would think Biden won. But debates often aren’t about policy, they’re about perception and the projection of strength. 

On both of these fronts, Biden badly stumbled. The Biden campaign explained the president’s hoarse and weak voice as Biden recovering from a cold, but his feeble appearance played into his biggest age-related vulnerabilities, leaving open the question of whether he can handle four more years in office. 

Neither candidate is the official nominee yet. The national political conventions haven’t happened, but it is unlikely that either party is likely to replace their candidate. Biden’s performance got a bit stronger as the debate went on, but he appeared incapable of delivering the same magnitude of vigor he has expressed in previous years.

Trump, too, did not walk away from the debates as a clear winner despite Biden’s shortcomings. He continued to spread falsehoods and embrace the conspiracy theories which most voters reject, including the proven lie that Democrat-led states were passing legislation “where you can execute that baby after birth”. Infanticide is criminalized in every state, and no state has passed a law that allows killing a baby after birth.

The muting of the candidates was likely intended to make the debate more orderly than the circus of the 2020 elections. The moderation (or lack thereof) also allowed Trump to spread falsehoods and hyperbole without being interrupted or corrected. By leaving fact-checking to the candidates, and with Biden unable to deliver in real time, Trump was free to spread a myriad of falsehoods. 

Trump used the same type of hyperbolic, bombastic language during this debate that appears to be unpopular with the American public. He did little to credibly defend his conduct on January 6th, and justified the concerns of many about his positions, especially on abortion (which has historically been a weak point for the Republican Party) and the US’ place on the world stage.

Ultimately, neither candidate walked away from the debate a clear winner. Despite Biden’s shortcomings, millions will still likely vote for him because he isn’t Trump. Americans have said they’re unhappy with their options, and in the biggest moment of the 2024 campaign yet, it was clear why. 

Personally, I can’t believe that this is what our choice for the 2024 election has become. These are not the two most qualified men to lead America. This debate was what was expected by many, and it developed in the worst possible way. On the one hand, Trump lied and exaggerated repeatedly throughout the debate, and did little to convince the American public that he was fit for office. His answers were rambling and did not make him seem like a man who has the ethics, commitment to the rule of law or moral compass we should expect from a president. On the other hand, Biden didn’t seem like he knew where he was half the time, and the feeble quality of his voice only fed into the image of Biden as an aged candidate who shouldn’t be the manager of a store, let alone the leader of the free world. I refuse to believe that the only choice for America today is between a convicted felon/compulsive liar and an incumbent who doesn’t appear to have the physical and mental capacity to be President today, let alone the next four years. I think that we not only can do better, but deserve better as a country. We should demand excellence from our leaders, and June 27th’s debate was anything but excellent.

Domestic Policy News

Andrea Stephen

Supreme Court Decisions

The Supreme Court’s 2023-2024 term has finally come to a close. This term saw the conservative-dominated Court (six conservative and three liberal judges) issue major opinions with serious implications for the future of the American justice system, administrative state, individual and civil rights, access to reproductive health and reproductive freedom, democracy, and more. While every case heard by the Supreme Court is important, we have chosen to highlight a few of the largest or more controversial cases this term.

Trump v United States: clarifying the scope of Presidential immunity, the Supreme Court makes it harder to prosecute former President Trump

This case, brought by former President Trump, asked the Supreme Court to determine if a former president can be shielded from criminal prosecution by presidential immunity for actions taken during their time in office. 

On July 1st, in a 6 to 3 opinion decided along ideological lines, the Supreme Court ruled on Presidential immunity. Writing for the majority, Chief Justice Roberts asserted that “the nature of Presidential power entitles a former President to absolute immunity from criminal prosecution for actions within his conclusive and preclusive constitutional authority. And he is entitled to at least presumptive immunity from prosecution for all his official acts. There is no immunity for unofficial acts”. The case is now being sent back to a lower court to determine how this ruling applies to specific acts taken by former President Trump during his time in office.

Writing for the dissent, Justice Sotomayor- joined by Justices Kagan and Jackson- railed against the majority’s opinion, arguing that the majority turned the president into “a king above the law”. The dissent highlighted the consequences of this ruling not only on efforts to prosecute Trump for actions taken to subvert the 2020 election, but on the future of American democracy as well. 

Notably, Sotomayor’s dissent specifically criticized the majority for not ruling out presidential immunity in relation to Trump’s involvement in the fake elector scheme, pressuring state officials to overturn legitimate election results, and leveraging mob violence on January 6th to influence the election certification proceedings.  As such, this dissent provides key insight as to how this ruling may hinder future criminal proceedings against Trump and influence his upcoming criminal trials. 

Fischer v United States: the Supreme Court’s Decision shakes up convictions for hundreds of J6 rioters

On June 28, the Supreme Court ruled that federal prosecutors improperly charged hundreds of Jan. 6 defendants with obstruction. This has upended many cases against rioters who disrupted the certification of the 2020 presidential election; many defendants charged under this statute might have their cases revisited or even have their convictions overturned.

Writing for the majority, Chief Justice John Roberts said that the government must prove that a defendant “impaired the availability or integrity” of records. Justices Amy Coney Barrett, Sonia Sotomayor and Elena Kagan dissented. Currently, 27 rioters are serving time in prison for only this felony. Nearly 80% of the 1,400 people charged in the attack on the Capitol were charged with trespassing federal property and assaulting/resisting a law enforcement officer, not obstruction. 

The ruling may also affect Donald Trump’s trial for allegedly trying to remain in power after his 2020 defeat; two of the four charges he faces are based on the obstruction statute, and he could move to have those charges dismissed. 

Ultimately, this ruling will likely have significant future implications for how prosecution of the rioters at J6 will be carried out, and that it will become much more difficult to charge defendants with obstruction in the future.

Loper Bright Enterprises v Raimondo: overturning the Chevron Doctrine, the conservative supermajority hinder the administrative state

In a 6 to 2 decision, the Supreme Court’s ruling in Loper Bright Enterprises v Raimondo overturned the landmark Chevron Doctrine. 

Considered to be an essential ruling for federal administrative law, the Chevron Doctrine emerged from the Supreme Court’s 1984 ruling in Chevron v Natural Resources Defense Council and was crucial to the functioning of federal agencies. Under the Chevron Doctrine, if a statute passed by Congress was unclear, ambiguous, or failed to address a specific issue at the center of a dispute, then a court must uphold federal agencies’ interpretation of the statute as long as it was reasonable. In this way, the Chevron Doctrine played a key role in the functioning of the administrative state, allowing federal agencies to uphold and enforce important regulations.

Writing for the majority, Chief Justice Roberts asserted that the Chevron Doctrine was fundamentally incorrect: Chevron was incompatible with the Administrative Procedure Act, a federal law that establishes the procedures federal agencies must adhere to and provides guidelines for courts to review the actions of these agencies. Roberts ultimately concluded that under the APA “it thus remains the responsibility of the court to decide whether the law means what the agency says”. Therefore, under this ruling, the Supreme Court essentially declared that courts, rather than agencies with highly specialized and extensive expertise, are better suited to answer the highly technical and scientific questions that emerge- and are crucial- when determining the meaning of ambiguities in federal statute.

Dissenting, Justice Kagan, joined by Justice Sotomayor, criticized the majority's ruling arguing that Congress regularly passed regulatory statutes containing ambiguities, and federal agencies with highly technical and specialized knowledge were better suited to determine the meaning of such ambiguities. Furthermore, the dissent emphasized that because the Chevron Doctrine had been precedent for 40 years, it had deep roots in the legal system such that overturning Chevron created a “jolt to the legal system”.

Ultimately, in overthrowing the Chevron Doctrine, this ruling undeniably weakened the authority and functioning of federal agencies while empowering courts. It comes as no surprise therefore that many view this ruling as part of the larger conservative movement to rein-in, or even dismantle, the administrative state. 

Garland v Cargill and United States v Rahimi: the Supreme Court grapples with the Second Amendment

This term, the Supreme Court issued two major decisions regarding the Second Amendment. 

United States v Rahimi asked the Supreme Court to determine whether federal law 18 U.S.C. § 922(g)(8)- “which makes it unlawful  for someone under a domestic violence restraining order to possess firearms”- violates the Second Amendment and is therefore unconstitutional.

Rahimi emerged in the aftermath of the Supreme Court’s 2022 decision in New York State Pistol & Rifle Association v Bruen in which the Supreme Court ruled that “courts should uphold gun restrictions only when there is a tradition of such regulation in U.S. history”. Put simply, under Bruen, laws are subject to a “history and tradition” test; upholding a law today requires the existence of a “historical twin law”. Mr Rahimi had been indicted under federal law 18 U.S.C. § 922(g)(8); following the Court’s ruling in Bruen, Mr Rahimi appealed his indictment arguing that the law was unconstitutional on Second Amendment grounds. Prior to reaching the Supreme Court, Rahimi’s case was heard in the U.S. Court of Appeals for the Fifth Circuit which ruled in favor of Rahimi: with reference to Bruen, the Court argued that as there were no sufficiently identical laws in U.S. history banning domestic abusers from possessing arms, federal law 18 U.S.C. § 922(g)(8) was therefore unconstitutional.

However, in a 8 to 1 opinion- with only Justice Thomas dissenting- the Court reversed the Fifth Circuit's decision, upholding federal law 18 U.S.C. § 922(g)(8) as constitutional. Writing for the majority, Chief Justice Roberts argued that “[w]hen an individual has been found by a court to pose a credible threat to the physical safety of another, that individual may be temporarily disarmed consistent with the Second Amendment”. Furthermore, the majority seemed to offer some clarification of the Court’s Bruen ruling, stating that some lower courts- i.e. the Fifth Circuit- seemed to misunderstand the historic test required by Bruen, and cautioned courts against interpreting Bruen as requiring such a strict historical test. Dissenting, Justice Thomas argued that the question at hand was not whether the government can strip an individual of the right to bear arms, but whether the government can strip someone subject to a protective order of their right to bear arms; Justice Thomas held that the government cannot do this.

In the end, by upholding a crucial federal gun regulation, and specifically doing so in the wake of Bruen, United States v Rahimi represents a major victory for gun-control. Furthermore, United States v Rahimi provides tentative hope for the future, demonstrating that the Court can exercise moderation when weighing the right to bear arms against other pertinent issues. 

On the other hand, in Garland v Cargill, the Court demonstrated their strong support for the Second Amendment and general disdain for major gun control regulations. 

Garland v Cargill was a highly technical case: it asked the Court to determine whether a ‘bump stock’ device is a machine gun as defined in 26 U.S.C. § 5845(b).

For context, the National Firearms Act includes a prohibition on the possession or transfer of machine guns. Garland v Cargill focuses on the ‘bump stock’- “an attachment that transforms a semiautomatic rifle into a weapon that can discharge at a rate of hundreds of rounds per minute”. For decades, the Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) did not categorize bump stocks as machine guns. However, following the Pulse nightclub mass shooting- which was carried out by a gun with a bump stock attachment- the ATF- under the Trump administration- reclassified bump stocks as machine guns and required individuals in possession of bump stocks to destroy them or drop them off at an ATF office to avoid criminal penalties or liability; basically, under this new rule, individuals possessing bump stocks could now face criminal charges.

In a 6 to 3 ruling, the conservative majority rejected the ATF’s classification of bump stocks as machine guns, holding that the ATF “exceeded its statutory authority by issuing a rule that classifies a bump stock as a “machinegun” under 26 U.S.C. § 5845(b)”. Writing for the majority, Justice Thomas asserted that if Congress wanted to ban all weapons with a high rate of fire they would have passed a law doing so; therefore, the ATF was incorrect in interpreting- and expanding- the federal ban on machine guns to include bump stocks. 

Dissenting, Justice Sotomayor- joined by Justices Kagan and Jackson- simply argued that bump stocks are machine guns. Sotomayor noted that Congress wanted to ban machine guns under the National Firearms Act because such guns “eliminated the need for a person rapidly to pull the trigger himself to fire continuously”; in the dissents view, a bump stock “serves that function”. Sotomayor concluded that the majority’s ruling  “eviscerates Congress’s regulation of machineguns and enables gun users and manufacturers to circumvent federal law.”

Notably, the majority’s opinion was highly technical, with Justice Thomas explaining in explicit detail the mechanics behind machine guns and semi-automatic weapons with bump stock attachments to support the majority's argument that bump stocks could not be classified as machine guns. Justice Thomas’ highly technical analysis is especially interesting in the wake of the Court’s ruling in Loper Bright Enterprises v Raimondo in which the Court overturned the Chevron Doctrine which held that courts should uphold federal agencies interpretation of federal statutes when interpreting a specific ambiguity. Considering the Court’s decision to overturn Chevron, the majority’s ruling here in Garland v Cargill- which struck down a federal agency's interpretation of a federal statute- further supports the larger argument that conservatives are seeking to dismantle the administrative state. 

Ultimately, the Supreme Court’s ruling in Garland v Cargill demonstrates that while the Court may be willing to moderately limit the right to bear arms as they did in Rahimi, this conservative-dominated Court is nevertheless focused on maintaining the right to bear arms to the largest degree possible.

Alexander v South Carolina Conference of the NAACP: to no one’s surprise, the Supreme Court ruled that South Carolina can use a racially-gerrymandered map that dilutes the power of Black voters  

In response to South Carolina’s adoption of a racially-gerrymandered congressional map which effectively diluted the voting power of Black voters across South Carolina, the South Carolina chapter of the NAACP and others challenged the constitutionality of this map arguing that “the Equal Protection Clause of the Fourteenth Amendment forbids the sorting of voters on the basis of their race, absent a compelling interest” and “the Fourteenth and Fifteenth Amendments also forbid intentional racial discrimination”. In the challengers’ eyes, South Carolina’s congressional map blatantly violated these constitutional principles and protections. 

Prior to being heard by the Supreme Court, the case was heard in federal district court; there, a panel of three federal judges unanimously ruled that South Carolina’s congressional map was unconstitutional on the basis of racial gerrymandering and racial discrimination. Yet, South Carolina appealed the decision to the Supreme Court arguing that the state moved Black voters for partisan reasons, and therefore the new congressional map did not violate the Fourteenth and Fifteenth Amendments. 

In a 6 to 3 opinion decided along ideological lines, the Supreme Court ruled that South Carolina did not need to redraw their congressional maps. The majority opinion, written by Justice Alito, reversed the district court’s ruling asserting that “[b]ecause the district court’s finding that race predominated in the design of South Carolina’s first congressional district was clearly erroneous, the district court’s racial-gerrymandering and vote-dilution holdings cannot stand”. Alito further argued that incorrectly attributing the racial effects a redistricted map to racial gerrymandering instead of partisan gerrymandering- as South Carolina contested- would enable courts and litigants to work around the Supreme Court’s 2019 ruling in Rucho v Common Cause which holds that federal courts should not consider cases regarding partisan gerrymandering.

Justices Jackson, Sotomayor, and Kagan dissented. Writing for the dissent, Justice Kagan argued that the majority’s ruling essentially tells legislators who want to use race, whether “as a proxy to achieve partisan ends” or to “straight-up suppress the electoral influence of minority voters” to “[g]o right ahead”. Due to this ruling, Kagan argued, state officials and legislators can circumvent accountability and scrutiny just by declaring that the maps were created considering factors other than race.

Crucially, this case has significant implications for the future of American democracy. Particularly, as political affiliation has increasingly become tied to identity politics, this ruling effectively enables state legislators and officials to racially gerrymander, diluting the voting power of minority groups and preventing them from electing individuals who truly represent their interests and values. Furthermore, this ruling insidiously provides state officials with a way to circumvent the protections established against racial gerrymandering and racial discrimination established under the Fourteenth and Fifteenth Amendments. 

Moyle v United States and FDA v Alliance for Hippocratic Medicine: in a shocking turn of events, the Supreme Court tentatively maintains access to reproductive healthcare 

Two years after the Supreme Court’s ruling in Dobbs v Jackson Women’s Health Center overruled Roe v Wade and ended the constitutional right to an abortion, reproductive freedom and access to reproductive healthcare continue to be contentious issues and the subject of legal battles across the country. This term, the Supreme Court heard two cases with major implications for the future of abortion access in the United States. 

Food and Drug Administration v Alliance for Hippocratic Medicine centered around the Food and Drug Administration (FDA)’s approval of the drug mifepristone. Mifepristone is used in combination with misoprostol to administer medication abortions, and mifepristone is used in over 50% of all abortions across the US. Mifepristone was initially approved by the FDA in 2000, and in 2016, the FDA further expanded access to mifepristone by allowing more practitioners to prescribe the drug. In the wake of the pandemic, in 2021, the FDA allowed certified distributors to distribute mifepristone via mail, and in 2023, the FDA allowed approved pharmacies to distribute mifepristone as well.

In the aftermath of Dobbs, anti-abortion groups began targeting mifepristone, seeking to hinder the sale of the drug; the Alliance for Hippocratic Medicine (AMH) is one such anti-abortion group. The AMH and others challenged the FDA’s approval of mifepristone, arguing that the FDA inadequately considered evidence when initially approving the drug in 2000.

Prior to reaching the Supreme Court, the case was heard first in a district court in which the judge sided with the AMH and suspended the FDA’s approval of mifepristone. The case was appealed and the U.S. Court of Appeals for the Fifth Circuit partially stayed the district court’s decision, upholding the FDA’s initial approval of mifepristone in 2000 but overturning the FDA’s 2016 approval expanding access to the drug.

When the case reached the Supreme Court, the Court was tasked with answering three questions:

1. Do the respondents- the Alliance for Hippocratic Medicine- even have Article III standing to challenge the FDA approvals of- and expansion of access to- mifepristone in 2016 and 2021?

2. Were the 2016 and 2021 mifepristone approvals “arbitrary and capricious”?

3. Did the district court correctly issue preliminary relief?

In a 9-0 decision the Court unanimously threw out the case ruling that the AMH lacked Article III standing to challenge the FDA’s “regulatory actions regarding mifepristone”. Writing for the Court, Justice Kavanaugh acknowledged while the AMH and others had “sincere legal, moral, ideological, and policy objections” to abortion and the FDA’s approval of mifepristone, ultimately, as the AMH could not demonstrate that they were harmed by the FDA’s mifepristone regulations, the AMH therefore lacked standing to challenge the FDA’s approval.

Crucially, while the ruling may appear to be a victory for pro-choice advocates, it is not a true win for the movement. In this ruling the Court failed to reach the merits of the case- that is, deciding whether the FDA was correct in approving and expanding access to mifepristone. As such, the Court has left this question- and access to mifepristone- open to future litigation by challengers who, unlike the AMH, have valid standing to challenge the FDA’s approval. Ultimately therefore, this ruling in FDA vs Alliance for Hippocratic Medicine, while a victory, is a tentative and temporary win at most. 

Moyle v United States was a legal challenge brought by the Biden Administration challenging Idaho’s restrictive abortion law which “criminalizes providing an abortion except in a few narrow circumstances, including to save the life of the mother”. The Biden administration argued that Idaho’s state abortion law was preempted by the Emergency Medical Treatment and Labor Act (EMTALA), a federal law which mandates hospitals receiving Medicare to provide “necessary stabilizing treatment” to pregnant individuals in emergency situations. Crucially, the Biden Administration’s argument hinged on the argument of federal preemption: under the Constitution’s Supremacy Clause, federal law is “the supreme Law of the land” and supersedes all state law to the contrary.

Prior to reaching the Supreme Court, the case was first heard in an Idaho district court; the federal judge sided with the Biden administration, issuing temporary injunction barring Idaho from enforcing its abortion ban where it conflicted with EMTALA. The case was appealed to the U.S. Court of Appeals for the Ninth Circuit in which the Court denied Idaho’s request for a stay of the injunction and maintained the district court’s preliminary injunction. Idaho then brought the case to the Supreme Court who, in January, issued a stay of the district court’s preliminary injunction- thereby allowing Idaho to enforce its abortion ban- and agreed to hear the case.

On June 27th, the Court dismissed the case as improvidently granted, and did not rule on the merits of the case. However, the Court released an unsigned order maintaining an order issued by an Idaho federal judge that temporarily prohibits Idaho from enforcing its restrictive abortion law. While the Court dismissed the case, nevertheless, Justices filed concurring and dissenting opinions. 

In a concurring opinion filed by Justice Kagan- joined fully by Justice Sotomayor and partially by Justice Jackson- Justice Kagan agreed with the Court’s decision to dismiss the case, stating that it was too early in the dispute for the Court to intervene. The opinion further agreed with the Court’s decision to dismiss its stay thereby reinstating the district courts temporary injunction barring Idaho from enforcing its abortion ban. Justice Kagan’s opinion did emphasize that she saw a clear conflict between EMTALA and Idaho state law such that some pregnant women experiencing grave risks to their health and wellbeing were not able to access medically necessary abortions.

Justice Jackson agreed partially with Kagan’s opinion: while Jackson agreed with the Supreme Court’s decision to dismiss its stay and allow the district court’s preliminary injunction to stand, Jackson disagreed with the Court’s decision to dismiss the case. Jackson argued that Idaho’s abortion ban clearly violated EMTALA, and therefore the Court should have ruled on the merits and in favor of the Biden administration.

Filing a dissent, Justice Alito asserted that the Biden administration’s argument that EMTALA superseded Idaho’s abortion ban was “plainly unsound”. In Alito’s view, EMTALA did not require Medicare funded hospitals to provide abortions, but rather “EMTALA’s text unambiguously demands that Medicare-funded hospitals protect the health of both a pregnant woman and her unborn child”.

Ultimately, like FDA v Alliance for Hippocratic Medicine, Moyle v United States should not be viewed as a decisive victory protecting abortion access. In failing to rule on the merits and dismissing the case back to the lower courts, the Court- exactly like they did in FDA- simply set aside the matter, thereby leaving access to abortion in Idaho- and across the country- open to future litigation. 

On a final note, recognizing the indispensable role the Supreme Court plays in maintaining and upholding American democracy, the administrative state, civil and individual liberties, and access to reproductive healthcare, it is important that voters consider the impact of their vote on the Supreme Court. For example, while Roe v Wade was overturned during the Biden presidency, this could not have happened without the appointment of three conservative justices- and the creation of a conservative supermajority- under the Trump administration. As Justices remain on the court for life, every appointment to the bench is crucial to the future of our rights, and the functioning of our democracy. 

U.S. Congress

Unshockingly, it has been a slow year for Congress as partisan rivalries have prevented many bills from receiving bipartisan support and passing. For example, following bipartisan demands for a border bill and extensive negotiations, in February, a group of Senators unveiled a bipartisan ‘border security bill’. Yet, when put to vote, the bill failed to get the necessary votes; and more notably, all but four Republican Senators voted against the bill.  Many view Republicans’ blocking of the border bill as part of a larger conservative strategy: Senate Majority Chuck Schumer argued that “Trump told his MAGA allies to kill it in its tracks so he could exploit the issue on the campaign trail… [a]nd Senate Republicans blindly and loyally followed suit”. As partisan considerations continue to polarize Congress, and especially as tensions are rising in the lead-up to the 2024 Presidential election, it will definitely come as a surprise if Congress manages to pass any major bill between now and the election. 

Congress managed to pass at least one major bill recently: a $1.2 trillion spending bill in March 2024. After over six months of negotiations over government funding, on March 23rd, Congress finally managed to pass a major spending bill, thereby ensuring the government remains funded for the rest of the fiscal year. While the bill provided funding for key U.S. government agencies- for example allocating $886 billion to the Department of Defense- the bill notably did not allocate funding for military aid to U.S. allies such as Taiwan, Ukraine, and Israel, but was included a month later in H.R.815 which passed a month later in April. Speaking about the bill, President Biden lauded the bipartisan compromise, noting that the bill “​​rejects extreme cuts from House Republicans and expands access to child care, invests in cancer research, funds mental health and substance use care, advances American leadership abroad, and provides resources to secure the border”.

The Biden Administration’s Executive Order on Migration

Throughout his Presidency, Biden has struggled with the issue of immigration, receiving bipartisan criticism of his migration and border policies, and consistently having polls reflect immense voter dissatisfaction to this end. Heading into the 2024 Presidential election, Biden evidently aims to improve voters’ perception of his migration policies. This aim is clear in Biden’s decision to sign a controversial executive order focused on migration. 

In June, Biden signed an executive order preventing “asylum seekers from crossing the southern border when a daily limit of crossings has been exceeded”. Justifying the executive order, Biden stated that Americans “must face a simple truth… [t]o protect America as a land that welcomes immigrants, we must first secure the border and secure it now”. 

While Biden evidently aimed to improve his track record on immigration and counter Republican criticism of his mishandling of the border crisis, the executive order had the opposite effect. The executive order has received widespread backlash, particularly with Democrats and progressives criticizing it as overly punitive and eerily similar to Trump’s asylum ban. With Biden already facing a deeply divided Democratic party, the backlash to his executive order comes as another blow to his administration and re-election prospects. 

Foreign Policy News 

Ellen Winters

G7 Summit

In June, President Biden attended the G7 summit in Puglia, Italy. The summit included the leaders of Japan, Canada, Germany, France, Italy, and the United Kingdom, along with representatives from the EU, UN, and a host of guest nations. The main topics discussed at the summit include the War in Ukraine and sanctions against Russian aggression, addressing the climate crisis, fostering development in technology and artificial intelligence, and supporting investment in developing countries’ economies. 

War in Ukraine

To reaffirm their support for the Ukrainian effort, G7 leaders announced new measures in place to sustain Ukraine’s fight economically and politically. Leaders announced a plan to provide $50 billion (USD) in financing for Ukraine, made possible by interest made on frozen Russian foreign assets. Russian sovereign assets, held in the European Union and other regions, were immobilized following Russia’s increased invasion in 2022. The assets have and will continue to be immobilized. While the war continues and these assets remain under G7 nation’s authority, interest gained will be used to support Ukraine’s military, economy, and infrastructure.

Beyond providing immediate funding for Ukraine, the G7 summit resulted in further sanctions on Russia to heighten the cost of war. These sanctions extend past the Russian federation and Russian nationals. They are designed to scrutinize foreign banks from dealing with the Russian economy, and restrict Russian access to U.S. software and technology services. Furthermore, the sanctions target the People’s Republic of China (PRC), which has contributed to upholding Russia’s economy throughout the war. A 2023 report by the U.S. Office of the Director of National Intelligence found that following February 2022, the PRC went to great lengths to increase trade with Russia. In 2022 alone, PRC’s purchases of Russian energy, including crude oil, coal, and gas, rose from $52 billion to $81 billion. The recent G7 sanctions hope to discourage China’s leveraging of the Russian wartime economy.

Climate Crisis

Reaffirming its COP28 commitments to address climate change and develop renewable energy capacity, the G7 summit released ambitious new initiatives. The goals are as follows:

1. Phase out Coal Power

2. Phase out unabated coal power generation during the first half of the 2030s

3. Deploy 1,500 GW of long-duration energy storage by 2030

4. Build Clean Supply Chains

5. President Biden announced plans to contribute $5 million to the Partnership for Resilient and Inclusive Supply-Chain Enhancement (RISE), which “supports low- and middle- income countries to invest in their economies and strengthen their engagement throughout critical minerals supply chains, helping to drive the clean energy transition and promote resilient supply chains”

6. Promote Collaboration on Nuclear Energy

7. The G7 is establishing a Working Group on Fusion Energy to share best practices and promote cooperation on research and development, recognizing that nuclear energy is a zero emissions energy source that can greatly reduce dependence on fossil fuels.

The extent to which these initiatives are actually implemented depends greatly on the domestic policy of all G7 states. Unfortunately, several G7 states, including the U.S., are facing turbulent elections, meaning that much of this agreement may be quickly thrown out, depending on what the succeeding administrations choose.

Humanitarian Concerns

On June 14, President Biden met with Pope Francis, who discussed humanitarian efforts, in terms of the Israel-Gaza conflict, the Russia-Ukraine war, and worldwide food insecurity. The leaders jointly called for an immediate ceasefire and hostage deal to put an end to the crisis in Gaza. President Biden acknowledged the Vatican’s work to address the humanitarian impacts of Russia’s war on Ukraine, including reuniting kidnapped Ukrainian children with their family.

Ukraine-Russia War

U.S.-Ukraine Bilateral Security Agreement

On June 13th, 2024, the United States and Ukraine entered into the U.S.-Ukraine Bilateral Security Agreement. This 10-year agreement pledges to:

1. Build and maintain Ukraine’s credible defense and deterrence capability

2. Collaborations in terms of security and intelligence

3. Strengthen Ukraine’s capacity to sustain its fight over the long term,

4.  building on efforts to bolster in Ukraine’s defense industrial base, and supporting its economic recovery and energy security

5. Accelerate Ukraine’s Euro-Atlantic integration

6. through Ukraine’s implementation of reforms to its democratic, economic, and security institutions in line with its EU accession goals and NATO’s program of reforms

7. Achieve a just peace

8. that respects Ukraine’s rights under international law, is underwritten by broad global support, upholds the key principles of the UN Charter, including sovereignty and territorial integrity, and includes accountability for Russia’s actions

9. Consult in the event of a future Russian armed attack against Ukraine

10. at the highest levels to determine appropriate and necessary measures to support Ukraine and impose costs on Russia

This agreement, not only between the U.S. and Ukraine, but within a network of G7 partners, opens the door to Ukraine’s path to NATO membership. While not yet a feasible option, the Biden administration is greatly optimistic that Ukraine will be bridged in NATO, once the appropriate roadblocks have been cleared. With this security agreement, President Biden stressed that “We are sending the clearest possible message today: the United States stands with the people of Ukraine as they defend their freedom and democracy.”

Long-Range Weapons and Increased Funding

This April, President Biden signed into law H.R.815, the National Security Act, which provides military funding to Ukraine and Israel, and humanitarian funding for Gaza. For Ukraine, this bill designates $61 billion dollars, distributed amongst the following categories:

1. Military equipment - $25.7 billion

2. Ukraine-related military activities - $17 billion

3. Economic support to Ukraine - $7.9 billion

4. U.S. forces in Europe - $7.3 billion

5. Humanitarian aid - $2.5 billion

6. Other U.S. governmental agencies - $355 million

President Biden released a statement following his signing of the law, stating that: “America stands with our friends. We stand up against dictators. We bow to no one - to no one, certainly not Vladimir Putin.”

Additionally, in May the Biden Administration authorized Kyiv to launch U.S. supplied weapons at targets within the Russian Federation. This particularly pertains to the Russian offensive against Kharkiv, as most missiles launched by Russia have come from across the border. With no way to eliminate these bases, Ukrainians have essentially been fighting with their hands tied, permanently on the defensive with no long-term strategic success. The U.S. had been hesitant to allow U.S.-produced weapons to cross the Ukraine-Russia border, as President Putin has suggested that such a move would make the U.S. an actor in the war. 

Indeed, following the Ukrainian strike on Sevastopol, a Crimean port, Russia immediately blamed the U.S. and “vowed retaliation”. American-supplied cluster munitions were reported to have been used in the attack. A Kremlin spokesperson “announced that ‘the involvement of the United States, the direct involvement, as a result of which Russian civilians are killed, cannot be without consequences’”. 

It is difficult to know to what extent the Russians are serious in the “consequences” they suggest the U.S. face. Russia has considered any U.S. aid to Ukraine to be considered a threat. In December of 2022, just 10 months into the war, the Kremlin issued a warning that U.S. military aid sent to Ukraine would aggravate the conflict and would not “bode well” for Ukraine. The future of the conflict remains challenging for Ukraine and its closest allies. Ukraine requires urgent aid, yet the U.S. and its allies are fearful of escalating a regional conflict into full-scale world war. The authorization of American weaponry to be used across borders is a significant step in Western support for Ukraine, and in demonstrating Biden’s unwillingness to give in to Russian threats. It will be notable to watch how this development shapes the conflict, and to see how Ukrainian allies will continue to support its defense, even with limited capacity to. 

Israel-Gaza Conflict

House Censures ICC

On June 4th, House Republican Chip Roy (TX-21) and colleagues passed H.R. 8282 (Illegitimate Court Counteraction Act). This legislation imposes “sanctions with respect to the International Criminal Court in any effort to investigate, arrest, detain, or prosecute any protected person of the United States and its allies.” The bill passed 247-155, 2 Present, with 205 yea votes coming from the Republican representatives, and the remaining 42 being from Democrats. The bill was introduced in response to the ICC applying for warrants for Israeli Prime Minister Netanyahu and Israeli Minister of Defence Gallant, for disregarding humanitarian law by using starvation as a method of warfare against the civilian population of Gaza.

This is not the first time Congress has voted as such. On June 11, 2020, the Trump administration issued an executive order targeting ICC officials and individuals involved in ICC investigations. This order came in response to ICC investigations concerning U.S. and Israeli nationals in Afghanistan and Palestine. This investigation was into grave crimes committed during the Afghanistan conflict - by Taliban and Afghan national forces, but also by the U.S. military and Central Intelligence Agency (CIA) personnel.

The general consensus, from floor speeches, was that “if they do it to them, they’ll do it to us”. American foreign policy is heavily reliant on protecting sovereignty, and as shown in this ruling, Congress will oppose any foreign regulations or intervention on their behavior. This vote calls into question the efficacy of international law, considering the United States’ reluctance to comply with the ICC, one of the only international organizations with designated “enforcement” mechanisms. A powerful case can be made for both sides - should national strength be prioritized, or international human rights norms? Perhaps the more important question is why the United States cannot do both - be a powerful leader while also abiding to basic norms of human dignity and rights. Is the call for us and our allies to adhere to basic standards of warfare really so difficult to respond to? The United States’ inability to respect these norms creates a hypocrisy in our national outlook. How can we criticize the Russian Federation, and celebrate the ICC’s warrants for Putin, while ignoring its criticisms of our own nation and our allies?

The future of American diplomacy is at a turning point. Do we pursue liberalism, human rights, and equality, values of justice and peace that we claim to possess? Or do we ignore global consensus and agreements, prioritizing our own military greatness over previously agreed upon norms that protect civilians and critical infrastructure in times of war? Pretending we adhere to the first path, while blatantly disregarding the actual actions of the ICC, signifies a great hypocrisy. Continuing on this route of diplomacy will only make the United States weaker, and our adversaries stronger. Pursuing liberalism while breaking the very values we supposedly purport sets a dangerous precedent of ignorance that only empowers Russia, China, Iran, and other adversaries to oppose us. And even worse - it justifies their skepticism of American involvement in foreign nations. 

We must end the hypocrisy in our military and diplomatic engagement. Guiding American foreign policy on pillars of honesty and transparency will only make us stronger. America has the strongest military in the world, and the greatest dominance in international affairs. There is no pressing need for us to evade concerns about human rights. Yes, some other countries are more corrupt; yes, some other countries continue to break international law. But this is our chance to differentiate ourselves, to motivate our allies, to expand our influence. A moralistic, truthful United States is more powerful than a hypocritical one. As we move into a world of unclear power balances, a strong, reliable America is needed to stabilize the values of prosperity and peace that our nation and allies have worked to instill throughout the past half century. America must abide by the values it asserts - our very credibility depends on it. 

Biden Administration Proposes Ceasefire Agreement

As mentioned earlier, H.R.815, the National Security Act provides security funding to Israel and humanitarian funding to Gaza. In regards to this bill, President Biden stated: “My commitment to Israel, I want to make clear again, is ironclad. The security of Israel is critical. I will always make sure that Israel has what is needs to defend itself against Iran and terrorists it supports.”

While continuing its support of Israel’s right to defend itself and strategic aims, the Biden administration has grown increasingly critical of its military conduct towards the civilian population of Gaza. H.R.815 contained $1 billion for humanitarian aid to Gaza, of which Biden stressed for Israel to “make sure all this aid reaches the Palestinians in Gaza without delay.”

International and domestic pressure to end, or at least pause the war, has increased significantly over the past several months, after several high-profile aid worker deaths and civilian deaths. On May 31st, President Biden announced his support for an Israeli-proposed peace plan. This plan is comprised of three stages:

1. Phase one (6 weeks): 

2. complete ceasefire and withdrawal of Israeli forces from Gaza

3. return of “a number of” hostages

4. release of “hundreds” of Palestinian prisoners

5. increase in humanitarian aid

6. Phase two:

7. “a permanent end of hostilities”

8. release of all living hostages

9. Phase three:

10. a “major reconstruction plan for Gaza”

11. final remains of hostages returned to their families

The plan has been backed by the United Nations Security Council, with 14 nations voting in favor of the ceasefire, and the Russian Federation abstaining. The resolution states that Israel has accepted the proposal, and urges Hamas to accept it. According to US Secretary of State Antony Blinken, the ceasefire is  reliant on Hamas’s acceptance of it, urging leaders in the region to “press Hamas to say yes”.

The plan is likely to face many hurdles. To begin, much of the wording in the proposed deal is incredibly vague. How does the administration hope to facilitate “a permanent end of hostilities” in what is perhaps the most fiercely divided conflict in the world, historically and presently? The deal is unpopular among far-right Israeli ministers, including Itamar Ben-Givir, and Bezalel Smotrich, who want the war “to continue until no trace of Hamas remains”. Hamas’s violent capture of 251 hostages on October 7th has made many Israelis unwilling to accept any terms of peace that allow Hamas to continue to exist as an organization. Some far-right members implore Israel and the U.S. to continue the fight, even if it means putting hostage and civilian lives at continual risk. On the other hand, Hamas will refuse to accept a ceasefire without guarantee of Israel forces withdrawing, which is unlikely to happen without hostages being returned, resulting in an endless, horrific loop. The situation is proving to be a diplomatic nightmare for the Biden Administration, caught in a war with historical boundaries too entrenched to allow for temporary peace. The Israeli government, a long-time ally and partner of the U.S., is digging into deeply nationalistic sentiments that the Biden Administration is becoming increasingly reluctant to accept. On the other hand, Hamas, a U.S. designated terrorist organization since 1997, is extremely challenging to negotiate with or incorporate into a long term peace plan. 

With no clear path to ceasefire, even with a U.S., UNSC backed resolution, the fates of the remaining 116 hostages and 500,000 Gazan civilians remain uncertain, as they face further war, food insecurity, and lack of access to healthcare or safe living conditions. The Biden Administration’s endorsement of a ceasefire deal represents a significant shift in U.S. foreign policy towards ending the war. However, it may be too little, too late for the hostages and civilians who remain caught in a brutal war between two sides unwilling to accept any compromise or pause in fighting.

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