Notre Dame Law Review Reflection Volume 96 Issue 1 Article 4 12-6-2020 One Ring to Rule Them All: Individual Judgments, Nationwide Injunctions, and Universal Handcuffs Paul J. Larkin Jr. John, Barbara & Victoria Rumpel Senior Legal Research Fellow at The Heritage Foundation; M.P.P., George Washington University, 2010; J.D., Stanford Law School, 1980; B.A., Washington & Lee University, 1977 GianCarlo Canaparo Legal Fellow at The Heritage Foundation; J.D., Georgetown University Law Center, 2014; B.A., University of California at Davis, 2011 Follow this and additional works at: https://scholarship.law.nd.edu/ndlr_online Part of the Constitutional Law Commons, Legal Remedies Commons, and the Supreme Court of the United States Commons Recommended Citation 96 Notre Dame L. Rev. Reflection 55 (2020) This Essay is brought to you for free and open access by the Notre Dame Law Review at NDLScholarship. It has been accepted for inclusion in Notre Dame Law Review Reflection by an authorized editor of NDLScholarship. For more information, please contact
[email protected]. ONE RING TO RULE THEM ALL: INDIVIDUAL JUDGMENTS, NATIONWIDE INJUNCTIONS, AND UNIVERSAL HANDCUFFS Paul J. Larkin, Jr. & GianCarlo Canaparo* One of the earliest decisions by the Supreme Court of the United States—Marbury v. Madison—sets forth one of the most ancient principles of Anglo-American law—viz., there is a judicial remedy for every legal wrong.1 Over the last three administrations, numerous inferior federal courts have taken that principle a giant step further. Those courts have decided that, when the government acts unlawfully, they may not only remedy the plaintiff’s injury but also protect everyone else by enjoining the Executive Branch from repeating the same conduct.2 Sometimes labeled “nationwide,” “universal,” J.R.R.