I am pleased to see that Judge Peter J. Messitte
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.