The scholarship of Professor Samuel Bray, '05, was cited by two US Supreme Court justices in two separate landmark executive power cases released earlier today.

In Trump v. Cook, in which the Court held by a vote of 5-4 that Lisa Cook can continue to a member of the Federal Reserve’s Board of Governors while her challenge to the President’s efforts to fire her moves forward, Chief Justice John Roberts in his majority opinion cites Bray’s 2025 article in the Journal of Legal Analysis Remedies in the Officer Removal Cases four times. 

In Trump v. Slaughter, in which the Supreme Court held in a 6-3 opinion that the president can use his executive power fire the head of the Federal Trade Commission without cause, Justice Sonia Sotomayor cites the same article, Remedies in the Officer Removal Cases, in her dissent.

These scholarly citations mark the fourth and fifth times that Bray’s scholarship has been cited in a US Supreme Court opinion this Term. He was also been cited by Justice Amy Coney Barrett in her concurring opinion in T. M. v. University of Maryland Medical System Corp.,  Justice Clarence Thomas in his concurring opinion in Sripetch v. Securities and Exchange Commission, and Justice Brett Kavanaugh in his dissenting opinion in Learning Resources, Inc., et al. v. Trump.