Haley Proctor
Notre Dame Law School
Associate Professor of Law
- Second Amendment
- Constitutional law
- Administrative law
- Federal courts
- Civil litigation
Proctor in the News
SCOTUS Blog
What is “trapped in amber”? An originalist explanation
August 07, 2026
Haley Proctor is an Associate Professor at Notre Dame Law School, where she researches and teaches about procedure, evidence, and the judicial system. She was previously a partner at Cooper & Kirk PLLC, where she remains of counsel, and a law clerk to Justice Clarence Thomas and Judge Thomas B. Griffith.
SCOTUS Blog
Narrow holdings with broad consequences
July 16, 2026
Haley Proctor is an Associate Professor at Notre Dame Law School, where she researches and teaches about procedure, evidence, and the judicial system.
Bloomberg
Trump’s Firing Power Ripples Through US Agencies After Court Win
July 02, 2026
Although the justices didn’t eliminate all job protections or the legal paths to challenge presidential firings, the court significantly narrowed them, according to Haley Proctor, a professor at Notre Dame Law School. The potential carve-outs included agencies with investigatory functions or that support Congress, and a small number of specialized courts, she said. Proctor said some fired officials might argue their agency more closely resembles the Federal Reserve, which the Supreme Court held this week is entitled to greater independence from presidential interference because of its long historical tradition. Still, she said, the fact that the justices overturned decades-old precedent that had limited the president’s firing power meant they wouldn’t be “eager” to embrace new exceptions. “I don’t think the door is that wide,” Proctor said. The next question, she added, would be the extent to which political checks restrain the president, now that the judiciary’s role is more limited.
ABC57
Local experts and politicians weigh-in on the Supreme Court's birthright citizenship ruling
Video
July 02, 2026
Haley Proctor, an Associate Professor of Law at the University of Notre Dame, clarified why that could mean that the decision may not be final: "Five of the Justices say that the 14th Amendment establishes this principal of birthright citizenship. Justice Kavanaugh writes a separate concurrence that says Congress could enact a law that goes along the lines of what President Trump's Executive order said."
CBS News
What to know about the Supreme Court rulings on presidential firings
Video
June 30, 2026
Notre Dame law professor Haley Proctor emphasized the rulings go beyond Trump.
Fox News
Gorsuch suggests Supreme Court's Trump ruling is opening move against administrative state
Video
June 30, 2026
Haley Proctor, a constitutional law professor at Notre Dame Law School, similarly described Gorsuch's opinion as a roadmap for future legal challenges. "I do think what Justice Gorsuch is pointing out is that this is the first step toward rethinking the way in which the administrative state is empowered and structured," Proctor said. Rather than simply expanding presidential authority, Proctor said the concurrence raises the possibility that Congress may ultimately have to reclaim powers it has delegated to agencies or assign certain responsibilities back to Article III courts. "If we're concerned about the amount of power that the Federal Trade Commission has, then the next step would be to reconsider giving that power to the Federal Trade Commission because some of the decisions that it's making could be made by Congress instead and some of the decisions that it's making could be made by the courts," she said.
CNN
The Supreme Court handed Trump an election case defeat. Is a bigger win for him coming?
June 30, 2026
“There are all these cases where the court seems to want to be out of the business of dealing with election issues,” said Derek Muller, an election law professor at the University of Notre Dame Law School.
The Hill
Supreme Court’s narrow gun decision kindles divisions, more questions
June 19, 2026
Haley Proctor, an associate law professor at Notre Dame, said the gap could be a sign that decision will similarly be narrow. “It does strike me as significant that the Court did not need to release them on the same date,” Proctor said in an email. “That suggests that Wolford will not say anything that meaningfully changes the Court’s core framework for analyzing Second Amendment challenges.”
USA Today
Supreme Court justice wants to scrap 'failed' Second Amendment test
June 19, 2026
But the fact that Thursday’s decision in favor of the drug user was a relatively narrow one could be a sign that the justices will also limit the impact of the Hawaii decision, according to Notre Dame Law School associate professor Haley Proctor, who specializes in the Second Amendment. Proctor said the Hawaii decision, which is expected by the end of the month, may not meaningfully change the court’s test for gun rules.
Reuters
As Clarence Thomas hits a milestone, his conservative stamp on US Supreme Court endures
May 04, 2026
"He began his time on the court often in dissent, and he stood his ground," said Haley Proctor, a University of Notre Dame law professor who previously served as a clerk for Thomas. "The justice's influence on the law has been profound," Proctor said. "And that is a consequence, not only of his many years on the court, but also of his persistence."
SCOTUS Blog
The who, what, and where of gun control
April 07, 2026
A Second Opinion is a recurring series by Haley Proctor on the Second Amendment and constitutional litigation.
SCOTUS Blog
The how and why of gun control
March 10, 2026
A Second Opinion is a recurring series by Haley Proctor on the Second Amendment and constitutional litigation. Haley Proctor is an Associate Professor at Notre Dame Law School, where she researches and teaches about procedure, evidence, and the judicial system. She was previously a partner at Cooper & Kirk PLLC, where she remains of counsel, and a law clerk to Justice Clarence Thomas and Judge Thomas B. Griffith.
SCOTUS Blog
Text, history, and party presentation
February 12, 2026
A Second Opinion is a recurring series by Haley Proctor on the Second Amendment and constitutional litigation.
SCOTUS Blog
Litigating gun rights: an interview with Pete Patterson
January 08, 2026
A Second Opinion is a recurring series by Haley Proctor on the Second Amendment and constitutional litigation.
SCOTUS Blog
Text and history, not history and tradition
December 10, 2025
A Second Opinion is a recurring series by Haley Proctor on the Second Amendment and constitutional litigation.
SCOTUS Blog
What James Madison thought about AR-15s
November 12, 2025
A Second Opinion is a recurring series by Haley Proctor on the Second Amendment and constitutional litigation.
SCOTUS Blog
Are judges good historians?
October 08, 2025
A Second Opinion is a recurring series by Haley Proctor on the Second Amendment and constitutional litigation.
SCOTUS Blog
Learning from Second Amendment litigation
September 09, 2025
A Second Opinion is a recurring series by Haley Proctor on the Second Amendment and constitutional litigation.