id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
inlawrev-25506	Goff, Christopher	Unequal Protection: Dispensing with Unilateral Presidential Waivers	2021	25	.pdf	application/pdf	11352	602	53	The 4-4 outcome upheld the judgment of the Fifth Circuit Court of Appeals, affirming an injunction that blocked the president’s executive order.2 That order would have protected up to five million immigrants from being subject to federal law that makes it a crime to enter the United States illegally.3 However, because the Supreme Court’s evenly divided membership “established no precedent,” the country did not receive the type of ruling expected beforehand when the Court “seemed poised to issue a major ruling on presidential power.”4 [Vol. 54:221 Obama’s to suspend deportation of Chinese nationals.8 Subjective enforcement of federal law constitutes a relatively recent trend, however, as George W. Bush was the first president to use categorical non-enforcement as a prominent policy- making tool.9 The Supreme Court has marginally addressed the issue of selective enforcement in the context of administrative law, choosing to “essentially leave to Congress, and not to the courts, the decision as to whether an agency’s refusal to institute proceedings should be judicially reviewable.	cache/inlawrev-25506.pdf	txt/inlawrev-25506.txt