Justice Samuel Alito noted that Scalia had illustrated how to apply textualism in the modern world.

Patel was born in New York to Indian immigrant parents, making him a U.S. citizen by birth under the 14th Amendment’s birthright citizenship clause. That personal background has drawn attention as the Trump administration pushes to narrow or reinterpret that same constitutional guarantee. It's unclear when Patel's parents became U.S. citizens.

The 14th Amendment of 1868 grants citizenship to all people born or naturalized in this country– including those previously enslaved. So with the Citizenship Clause on the line now, Johnson warned that Trump’s attack could impact the rights of Black descendants of slavery.