Samuel Bray
John N. Matthews Professor of Law
- Nationwide injunctions
- Constitutional Law
- Civil Procedure
- Equity
- Remedies
Bray’s Latest News
Bray in the News
Washington Examiner
Supreme Court’s death knell to universal injunctions changes Trump legal landscape
July 02, 2025
Samuel Bray, a law professor at Notre Dame Law School, spelled out why he believes the birthright citizenship order will still be paused...
Law360
Justices Face Busy Summer After Nixing Universal Injunctions
July 02, 2025
...Samuel Bray, a University of Notre Dame Law School professor.
Fact Check
How the Supreme Court’s Ruling on ‘Universal Injunctions’ May Affect Birthright Citizenship
July 01, 2025
Because plaintiffs still have time “to switch from universal injunctions to other avenues like class actions” challenging the administration’s policy, Samuel Bray, a professor of law at the University of Notre Dame, said he believes that the Supreme Court’s ruling will not result in a change to birthright citizenship.
Supreme Court’s death knell to universal injunctions changes Trump legal landscape
July 01, 2025
Samuel Bray, a law professor at Notre Dame Law School, spelled out why he believes the birthright citizenship order will still be paused as it is...
The New York Times
The Supreme Court Is Watching Out for the Courts, Not for Trump
June 30, 2025
By Samuel Bray. Mr. Bray is a law professor at the University of Notre Dame.
The Washington Post
Trump says he will move aggressively to undo nationwide blocks on his agenda
June 30, 2025
“The Supreme Court has fundamentally reset the relationship between the federal courts and the executive branch,” Notre Dame Law School professor Samuel Bray, who has studied nationwide injunctions, said in a statement. “Since the Obama administration, almost every major presidential initiative has been frozen by federal district courts issuing ‘universal injunctions.’”
NBC News
After criticism from MAGA world, Amy Coney Barrett delivers for Trump
June 30, 2025
Barrett defenders dismiss suggestions she would be influenced by negative comments from MAGA world, with Samuel Bray, a professor at Notre Dame Law School, saying her ruling that limited nationwide injunctions simply shows her independent qualities as a judge. “It should reinforce the sense that she’s her own justice and she’s committed to giving legal answers to legal questions. We shouldn’t be looking for political answers to political questions,” he said.
Reuters
Trump wins as Supreme Court curbs judges, but may yet lose on birthright citizenship
June 30, 2025
"I do not expect the president's executive order on birthright citizenship will ever go into effect," said Samuel Bray, a Notre Dame Law School professor and a prominent critic of universal injunctions whose work the court's majority cited extensively in Friday's ruling.
Bloomberg
Trump Runs Up Supreme Court Winning Streak, Amassing More Power
June 30, 2025
A prominent critic of nationwide injunctions, Notre Dame law professor Samuel Bray, hailed the decision — but also predicted a surge of class action suits and new court orders blocking the citizenship policy.
Los Angeles Times
Supreme Court limits judges’ ability to block Trump’s birthright citizenship ban
June 30, 2025
Notre Dame law professor Samuel Bray, an expert and critic of nationwide injunctions, hailed Friday's ruling but predicted it will not allow...
Newsweek
Map Shows States Where Birthright Citizenship Still Allowed in US
June 27, 2025
Professor Samuel Bray, a nationwide injunctions expert at Notre Dame Law School, told Newsweek that there would likely be litigation now on two fronts—Firstly, the states that want broader injunctions against Trump's executive order, and secondly, a "surge of new class actions" against how the executive order will be enforced.
Politico
Supreme Court hands Trump major win
June 27, 2025
It’s a big day for Samuel Bray, a law professor at the University of Notre Dame. His work on this issue is cited extensively in the majority’s opinion — a notable achievement for any academic.
NPR
What is a universal injunction and how did the Supreme Court limit its use?
June 27, 2025
"An injunction is an order by a court telling somebody to do something or not do something," explains Samuel Bray, a law professor at the University of Notre Dame. Usually injunctions protect the parties to the case. But a universal injunction "controls how the federal government acts toward anyone." He says universal injunctions are "a recent innovation" and their use has seen "a meteoric rise over the last 10 years" in tandem with an increase in executive orders issued by the administrations of presidents Barack Obama, Trump and Joe Biden.
NBC News
Supreme Court birthright citizenship ruling sparks new round of legal fights
June 27, 2025
Samuel Bray, a critic of nationwide injunctions at Notre Dame Law School whose work was cited in the ruling, said both the states and individual plaintiffs can still get broad injunctions against the birthright citizenship executive order, potentially even on a nationwide basis. "I don't expect the executive order will ever go into effect," he added.
BBC News
Supreme Court curbs judges' power to block Trump's orders in birthright citizenship case
June 27, 2025
Samuel Bray, a Notre Dame Law School professor and expert on nationwide injunctions, said the ruling "has fundamentally reset the relationship between the federal courts and the executive branch".
Bloomberg
Trump Wants to Make It More Expensive to Sue Over His Policies
June 13, 2025
University of Notre Dame Law School professor Samuel Bray, a proponent of injunction bonds, said courts should account for whether litigants have the ability to pay.
NBC News
'We're not stopping': Trump officials raise the stakes in showdowns with judges
March 18, 2025
But in the case of the deportations over the weekend, said Samuel Bray, a professor at the University of Notre Dame Law School, Trump officials were in contempt of Boasberg’s order in his view.
Associated Press
Texas judge says abortions can resume, but future uncertain
October 08, 2021
“It does feel novel for the federal government to sue a state on this relatively diffuse basis,” said University of Notre Dame law professor Samuel Bray. “But novel things happen. The way the Texas statute is set up is novel. Novel serve, novel return.”
The New York Times
Texas Abortion Case Highlights Concern Over Supreme Court’s ‘Shadow Docket’
September 02, 2021
“I don’t think anyone thinks it is good to have a lot of last-minute requests for emergency relief that the court has to focus on and decide,” said Samuel Bray, a University of Notre Dame law professor who testified about the shadow docket this summer before President Biden’s commission studying possible Supreme Court changes.
Marketplace
Why “equity” can mean “cash” in real estate and “fairness” in everyday language
March 11, 2021
According to a 2016 paper about the definitions of equity by Samuel Bray, a professor of law at Notre Dame, “There were also certain kinds of suits that were typically brought in equity [courts] because the chancellor had developed special doctrines for them — especially suits about trusts and mortgages.