I am pleased to see that Judge
Peter J. Messitte's
ruling today in
District of Columbia v. Donald J. Trump (the DC/MD Emoluments Clause case) draws upon
the research of my
Georgetown Law colleague
John Mikhail in the opinion's substantial discussion of the historical record. Also, after considering it at length, Judge Messitte also rejected
Seth Barrett Tillman’s argument in an amicus brief that the presidency was not covered by the Foreign Emoluments Clause.