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For decades, California’s Central Coast watched major economic booms happen elsewhere, writes Doug Erickson, co-founder of Santa Cruz Works. Now, Monterey Bay DART, Joby Aviation, UC Santa Cruz and a coalition of both regional and international partners are building a new aviation ecosystem that is attracting investment, workforce funding and international attention.
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In O Horizon, a Chatbot Promises to Take the Pain Out of Bereavement
Madeleine Rotzler’s new film, O Horizon, offers an odd vision of dystopia, even as it’s billed as a “sci-fi comedy drama.” The film itself is not always much to look at, but sometimes a film in its very strangeness can reveal a great deal, precisely because of all that it obscures. After all, so much of what matters these days is happening out of sight, suppressed by algorithms, hostile media, and even more hostile governments, and increasingly one must learn to look under the surface of simple things. Rotzler’s film gets its title from the layer of decomposed plant matter on the forest floor, the “O horizon,” but it’s what’s lying beneath O Horizon that truly matters.
In a near-future New York, Abby (Maria Bakalova) works in a neuroscience lab tracking the brain waves of monkeys, struggling to deal with the recent death of her father, played by David Strathairn. An intrusive, Siri-like AI assistant encourages her to visit a shabby-looking tech start-up called Seeking a Friend Store; there, a lone employee played by Adam Palley offers to recreate someone you’ve lost or are missing. After uploading a parcel of photos, documents, and other archival material to its servers, the company creates a digital avatar that you can call on your phone whenever you like. After some initial reluctance, Abby creates a digital version of her dead dad, and soon begins talking to it as a means of managing her grief as she tries to go forward in her life.
As an AI chatbot, her dead father acts like all AI chatbots: supportive, deferential, complimentary. The AI is always there with a new prompt to fill up dead air (“Tell me something fun that happened today,” “What’re you up to tonight? Having fun?”) or a little ego boost (“Dr. Williams is so lucky to have you. You’re excellent.… Somehow you’ve managed to develop excellence in all that you do. Don’t let anyone tell you otherwise”). It’s always working to keep her engaged and affirmed, and anytime there’s any friction between the two of them, it backs off, eager to keep her on the line. If Strathairn’s dialogue wasn’t actually written by ChatGPT, the script does an excellent job of imitating it, and the bot’s lines have all the hallmarks of an LLM: cloying and irritatingly sentimental.
These are strange scenes. For narcissists, incels, and sociopaths, the appeal of a chatbot is that it will always tells them exactly what they want to hear, so you can imagine how uncomfortable it is to listen to such a thing telling someone else what they want to hear. As the platitudes and clichés dribble out of Abby’s phone, not even an actor with Strathairn’s delivery can save them.
We never learn how much Abby pays for her subscription, but in real life these businesses have a financial incentive to get their users hooked, so to speak, on their product. As Mary-Frances O’Connor, professor of clinical psychology at University of Arizona, told Scientific American’s David Berreby in 2025, the danger here is that people struggling with grief can be uniquely vulnerable to Big Tech’s long-honed engagement and gamification strategies. Researcher Nore Lindemann has further noted that “users are likely to become dependent on their bots, which may make them susceptible to surreptitious advertising by deathbot providing companies and may limit their autonomy.”
That vulnerability offers real possibilities. For emerging companies like You, Only Virtual, HereAfter AI, Super Brain, and Silicon Intelligence, grief represents an exciting new market. Researchers are already beginning to identify the obvious financial incentives for such companies to alter the “informational bodies” of the dead to increase engagement and revenue. Rather than moving people through the process of grieving, AI companies would seem to benefit more from keeping them in the phase of acute bereavement, distorting their memories to give them what they want, all the while promising the false allure of being perpetually free of loss. Indeed, one wonders if Abby’s dad was really this asinine in life, or if Seeking a Friend Store has already tweaked his personality to keep her paying subscription fees.
While Rotzler’s movie doesn’t much explore the ethical implications of what it might mean to get addicted to a product that promises to take the pain away, it does depict what a world without pain might look like. And it turns out to be a truly banal one. For it’s not just the dialogue. Strathairn’s chatbot doesn’t push back or try to challenge or trouble Abby in any way, and strangely, O Horizon’s plot does not try to challenge or trouble the viewer, either. Throughout its hundred-minute run time, hardly anything happens. There is no real conflict, no real rising tension, no climax, no real denouement.
O Horizon gives you what AI thinks you want: no struggle, no tension, nothing unpleasant, no pushback.At one point, the AI develops the ability to call Abby of its own initiative—you think this may signal a turn in the narrative, some malevolent warning about technology getting out of control, but it doesn’t. At another point, Abby begins dating a man named Douglas (Avi Nash), and the viewer thinks maybe he will turn out to be a jerk, but he doesn’t. The viewer thinks perhaps her AI dead father will get jealous, or otherwise turn haywire. He doesn’t. You may think Abby will have to learn to let go of her father to be with her boyfriend, but she doesn’t! The few conflicts that do arise have such low stakes that they are resolved within minutes and forgotten almost immediately. No character conflict has any kind of lasting ramification or seems to matter for any serious length of time. Anytime it seems like there might be any kind of friction, the plot backs off.
It’s as if the story is as deferential and sycophantic as AI itself. O Horizon gives you what AI thinks you want: no struggle, no tension, nothing unpleasant, no pushback. It is a movie made by real humans, but it feels like it’s made by AI, made without an awareness of what makes film interesting or ultimately pleasurable. For one of the most basic reasons we experience narrative art, be it a film or a novel or a television show, is some kind of tension, some kind of drama. No one actually wants a smooth, flat surface. We do not want art to smile placidly back at us for one hundred minutes telling us we’re excellent, that the world is lucky to have us, that nothing matters.
We’ve known this for thousands of years; it’s one of the most basic lessons of Aristotle’s Poetics. Catharsis—the purging of negative emotions that happens through the experience of watching something difficult; of dealing with a character’s actual pain and suffering; of being engaged with issues of actual tension, drama, hardship, impossible decisions, insurmountable odds, tragedy, and resolve in the face of despair—matters not just because it allows us a safe venue to release these emotions, but because it gives us perspective on our own troubles and hardships. Grappling with pain through art is one of those very existential things that makes us human, that allows us to experience the world fresh and anew. That word itself—catharsis—has remained so elusive since Aristotle’s days, so hard to pin down, precisely because it’s hard to say exactly what it is we need from great art. There is no simple definition, no easy formula, no predictable algorithm that can deliver it to us. It seems cheesy to have to say this, but we live at a moment when AI-generated art that fails to deliver this is being passed off as legitimate, and sometimes just stating the obvious becomes an act of resistance against this dreck.
Dulled of sensation, the world of O Horizon is emptied. The same opiate that griefbots would offer the grieving, Rotzler’s narrative offers her viewers: soporific, painless.
In a strange way, the fantasy of painlessness is particularly fraught for Rotzler. Her previous films appeared under her maiden name, Sackler. Her grandfather, Raymond Sackler, was one of three brothers who founded Purdue Pharma, the pharmaceutical company behind OxyContin; her father, Jonathan, sat on its board and was its vice president for years.
While Rotzler herself has never worked for Purdue Pharma, in 2023 Artnet reported that a number of the production crew of O Horizon became uncomfortable during filming, viewing Abby’s relationship with her father as being an autobiographical depiction of Rotzler’s relationship with her own father, who died in 2020, and an attempt to whitewash his image.
In the decades when Jonathan Sackler was involved with Purdue Pharma, it generated billions of dollars by distributing Oxycontin throughout the United States and abroad. In 2007, the company pleaded guilty to misleading the public about the addictive properties of OxyContin, and the year Jonathan died the company reached a settlement in which it admitted that for years it had “knowingly and intentionally conspired and agreed with others to aid and abet” doctors in dispensing the drug “without a legitimate medical purpose.” (The consulting firm McKinsey & Company additionally agreed in 2024 to a $650 million settlement for its work in helping “turbocharge” Purdue’s sales of OxyContin during the epidemic.) The Centers for Disease Control and Prevention estimates that between 1999 and 2018 alone, 450,000 Americans died from opioid overdoses.
The father of O Horizon is a kindly, generous man—a sculptor, a fan of David Bowie, and a reader of scientific journals. It was this depiction that apparently caused friction among the crew during filming. “The script is extremely parallel to Madeleine’s experience of the loss of her dad, and clearly very related to what he did with drugs,” set dresser Caroline Pigou told Artnet. “Everyone on the crew would talk about how fucked up and weird it was that this movie was getting made in the first place.”
Rotzler has insisted that the film is not autobiographical. “This film is about artificial intelligence and there are no parallels between my father or his work and the characters in the film,” she told Artnet through a representative. Fine. That’s her take. Still, the film’s theme of painlessness is one that resonates with the family business of selling pain relief; and the film’s obliviousness to the shallowness of the AI bot’s consolations echoes with Purdue’s years of denying the dangers of its opioids.
Everywhere, it seems, we are faced with bullshit technology and bad art that offer false promises to take away all our pain.It’s not the first time Rotzler has proven determined to ignore the ways in which her films might seem to audiences to be in conversation with her family’s scandals. In a New Yorker feature on her earlier work, the documentary It’s a Hard Truth Ain’t It and the feature O.G., both filmed inside an actual penitentiary in Indiana, Nick Paumgarten wrote that “one might suppose that Sackler’s concern and sympathy for the incarcerated is some kind of expiation,” given that so many incarcerated Americans are there for opioid-related offenses, but she “thinks this is baloney.… It pains her to think that the perception of her project, and of the hard work of everyone involved, would be tainted in some way by her pedigree.” In Empire of Pain: The Secret History of the Sackler Dynasty, Patrick Radden Keefe relates how Jeffrey Wright, the star of O.G., emailed her before the film opened, asking her to address the “elephant” in the room: why so many of the men were in the prison where they’d been filming. “You never spoke to me about any of that. I was aware and only once tried to broach the subject with you. You didn’t open up about it.” As the premiere approached, Wright wanted to know: “Do you think you should take into consideration that this will become part of the dialogue around these films?” According to Keefe, she never wrote Wright back.
If there’s an animating impulse in O Horizon beneath its facile resolution of grief, it’s denial: the steadfast inability to contemplate how this story of a daughter conjuring a smoother, simpler version of her late father might play to audiences who have followed years of news of the opioid epidemic and the Sacklers’ central role in it.
O Horizon is not much of a thing in and of itself. But it offers an almost perfect distillation of our relationship to pain in 2026. Everywhere, it seems, we are faced with bullshit technology and bad art that offer false promises to take away all our pain, all the while completely misunderstanding what that pain is, why we suffer it, and what it means to actually endure it.
Rotzler’s uncle Richard Sackler once wrote of those overdosing from his company’s drug, “These are criminals.… Why should they be entitled to our sympathies?” Why indeed. I think of Susan Crathern, whose son Kevin broke two teeth on the playground when he was 10 and was given OxyContin for the pain, his mother assured by the dentist that it was not addictive. Ten years later, he died from an accidental overdose after years of struggling from addiction. In her 2020 testimony to Congress on the damage wrought by the opioid crisis, Crathern wrote: “In my mind his death is a truth that can’t be true.”
This is how grief actually is for too many people, down in the wreckage, where it is a paradox that can’t easily be solved, one that can’t be glibly assuaged with pabulum and clichés, a thing not to be solved with subscription fees, engagement algorithms, and prefabricated compliments but faced with rage and guilt and sorrow and carried every day without reprieve. For too many people’s lived reality, grief is the unimaginable weight of memories, the ugly truth that can’t be true. There’s no money to be made from it, so it gets hidden away, pushed down out of sight, past the detritus, down here, below the horizon.
The Most Underappreciated Part of the Bipartisan Housing Bill
President Donald Trump surprised just about everyone in Washington, Republicans and Democrats alike, when he announced on Wednesday that he was canceling an afternoon signing ceremony for the biggest housing bill to pass Congress in decades. He’s holding the bill hostage over his unreasonable demand that lawmakers first pass the Save America Act, the Republicans’ voter suppression bill, which doesn’t have the votes to pass the Senate. As Democratic Senator Elizabeth Warren, a key supporter of the bill, said, “He could be over here trying to claim a victory lap. And instead, he’s saying no, no he doesn’t want anything to do with it.”
The bill will automatically become law in ten days if Trump refuses to sign it. (He could also veto it, but it passed with veto-proof margins.) So one way or another, more than 60 measures will take effect with the goal of increasing housing by waiving some regulations, increasing grants to communities that encourage building, updating rules on manufactured homes, and preventing large investors from buying single-family homes. Much of the provisions were big asks from the abundance movement.
Proponents of these measures hope that they will increase housing supply and therefore lower prices, putting homeownership back within reach for middle-class families. But there’s a smaller provision that could be just as important. The bill includes pilot programs to address a gap in the housing market which keeps families from getting mortgages on already inexpensive homes because it’s often not profitable for lenders to issue smaller mortgages. Addressing this gap could bring the best idea of the abundance movement—that public policy should focus more on increasing housing supply—to distressed and rural communities where aging, inexpensive homes already exist.
The provisions deal with “small-dollar mortgages,” defined as those less than $100,000, for homes that are often called “naturally affordable”—which is to say, cheap. They’re often priced affordably because they’re small, old, in a less expensive neighborhood, or some combination of the three. Such homes are not a big part of the market, but they could be exactly what working-class families who want to move from renting to homeownership need, especially in certain areas of the country.
“These small-dollar, or low-cost, homes comprise only about 3 percent of active listings, that’s about 32,000 homes that are under $100,000 today,” said Aniket Mehrotra, a policy coordinator at the Urban Institute’s Housing Finance Policy Center. “However, in rural areas of the country the share of active listings is greater.”
Yuliya Panfil, director of the Future of Land and Housing program at the nonpartisan think tank New America, calls this “affordable housing hiding in plain sight.” While many homes are simply too expensive for low- and moderate-income families to buy, these are well within their price range but difficult if not impossible to get mortgages approved for. “The result of these often-invisible challenges is that millions of starter homes sit in a financing no-man’s-land — too complicated for most buyers to access and too overlooked by policymakers to fix,” Panfil wrote at Bloomberg CityLab. “We are struggling to build new homes fast enough as millions of existing affordable homes quietly go to waste.”
Researchers at The Urban Institute in 2018 documented the problems families face when trying to buy these less expensive homes. “Lenders weren’t originating small-dollar loans even where affordable properties existed, locking out working-class families not because of creditworthiness, but because the loan economics didn’t work for lenders,” said Alanna McCargo, a Senior Fellow for Inclusive capitalism at the Clinton Foundation and non-resident Fellow at the Urban Institute who worked on the original report. This dynamic keeps families out of homeownership, pushes them into less secure loans, or encourages them to buy more expensive homes they struggle to afford.
It’s unclear what banks need in order to issue more of these loans, so the bill creates pilot programs to study and implement possible fixes, including requiring the Consumer Financial Protection Bureau to study compensation rules and caps on fees to mortgage lenders to potentially encourage more small-dollar lending, and a Housing and Urban Development pilot program to increase access to these loans.
But encouraging more lending isn’t the only solution. Much of this housing stock is in smaller cities far from the booming coastal megalopolises where abundance proponents live, and the homes are also aging. Even if families find willing lenders to buy an older home, the houses may not appraise or pass inspection. Families already living in them are also often locked out of financing to make necessary repairs that would enable them to put their homes on the market again and move on, freeing them up for new families to buy.
The bipartisan housing bill only provides limited provisions on rehabilitating old homes, primarily for elderly and low-income homeowners, and doesn’t provide new funding for existing grant programs. “Focus on this bill is predominantly on building new housing,” Mehrotra said. “However, we have an aging housing stock in this country. The majority of our housing stock was built before 1980, which indicates that many homes are in need of repair, particularly in certain markets, like in rural areas, [and] in cities like Philadelphia or Baltimore, and so it is critical that we also prioritize home rehabilitation.” Developers are also often unwilling to renovate or rebuild older homes in neighborhoods where they can’t get their money back. Mehrotra said that proposed legislation to tackle that problem was not included in this bill but could be revisited in the future.
Still, Panfil’s colleague at New America, Sabiha Zainulbhai, called the measures “exciting progress on figuring out how to unlock this critical housing supply for first-time and low and moderate income buyers, especially at a time when homeownership is inaccessible for a growing segment of the population.”
There’s other work to be done on housing, of course, like more rental assistance for low-income families, which is a nonstarter in this GOP-controlled Congress. And while Trump sits on the housing bill, many American families have already given up on the homebuying dream because they simply can’t afford it. This bill won’t fix those problems overnight. “Implementation takes time, and families who need a small-dollar mortgage today and thousands of families already left behind by rising home prices over the past decade won’t benefit from this,” McCargo said. “But it’s a step in the right direction, and one we’ve been working toward for years.”
The Prairieland Verdicts Are a National Emergency
It’s rare for a judge to acknowledge that they are handing down a prison sentence for political reasons. But that is precisely what chief district judge Reed O’Connor stated from the bench in a North Texas federal courtroom this week, during the sentencing of eight defendants in one of the Prairieland cases, so named for the defendants’ participation in a July 4 demonstration at the Prairieland Detention Facility, a federal immigrant detention camp in Alvarado, Texas. In a hearing on Tuesday, as O’Connor handed down sentences of decades in prison, the judge said he was ordering the maximum allowed in each case because “the state wants to send a message to anyone who shares a similar ideology,” according to a support committee for the defendants.
The bluntness of the sentiment struck some of the defendants’ supporters hard. “We’ve always known the U.S. government has punished dissent every chance possible, but for it to be so blatantly pointed out was such a hit,” said Kels Menchaca, a member of the DFW Support Committee, which provides practical support to the defendants and works to educate the public about these cases. The group is now preparing for the long-haul support the defendants will need over what may be decades in federal prison, pending appeals or possibly pardons. The Prairieland cases are an emergency in their own right, but they are also a warning. This is not the last case of dissent to be punished so severely by the Trump administration. Defending them could help us stop the next one.
The Prairieland cases should be understood as the government’s effort to heroize ICE in the face of community defense efforts to stop mass deportations, and to shift the blame for political violence from federal officers to the left. Last summer, in Los Angeles and other cities, people took to the streets in massive numbers to demand an end to the flood of federal officers assaulting and abducting people profiled as immigrants in chaotic operations that were often captured on video by teams working for the government. As people organized regular demonstrations at federal sites used for the mass detention of immigrants, Trump threatened to send in troops to stop them. No one knew how these events would escalate, but it was clear the administration was looking for scapegoats.
On July 4, 2025, community members held a demonstration outside the Prairieland Detention Facility. As the demonstrators made noise and set off fireworks outside that night, hoping the people locked up inside would hear them, a few split off. A security booth and some employees’ cars were graffitied, and a security camera was broken. The detention center guards told the demonstrators to leave; most did. A police officer arrived on the scene, his weapon drawn. One of the remaining demonstrators was open-carrying a rifle. An officer was shot in the shoulder. He was briefly hospitalized and survived. Within hours, what followed was garnering breathless coverage in right-wing media as an antifa assault on a federal facility.
There was no such assault. But the facts weren’t enough to stop the government from punishing eight people with effective life sentences, convicting them of “providing material support to terrorists” for acts such as printing and distributing leftist zines, joining an anarchist book club, communicating on the same messaging app, or having visited the same shooting range. These people are now facing 30-, 50-, 70-, and 100-year prison sentences. “These are friends,” Menchaca said. “These are people’s family, and they’re being given extraordinary sentences for things that are supposed to be protected actions. Fireworks on the 4th of July being called explosives and terrorism? Political literature is something worth taking 30 years of someone’s life?”
In all, 21 people were arrested for their alleged connection to the Prairieland demonstration, some that night, but many much later. In a press release on July 8, ICE claimed that “nearly a dozen violent assailants equipped with tactical gear and weapons attacked the Immigration and Customs Enforcement’s Prairieland Detention Facility.” Todd Lyons, then the acting director of ICE, used the arrests to hammer home the administration’s narrative. “This is precisely what we have been warning against, as disinformation and dangerous politically motivated rhetoric spreads,” Lyons said. The department promised terrorism charges, and “vowed” to charge “anyone obstructing ICE operations or assaulting federal law enforcement officers.”
The government’s story diminished before any of the defendants made it to court. Multiple shooters became one, and up to 30 rounds fired dropped to less than a dozen, as Steven Monacelli found in an investigation for The Barbed Wire. Months passed before the defendants, some of whom remained in custody, were arraigned. But in that interval, the president issued an executive order claiming to designate “antifa” as a “domestic terrorist organization” (there is no such designation), and signed a national security memo authorizing sweeping investigations for alleged “political violence” from the left. Finally, when grand jury indictments were made public, the official story had settled: The Department of Justice had taken down a “North Texas antifa cell” that had “created and distributed insurrectionary material called zines,” “dressed in ‘black bloc’—dark clothing with head and face coverings,” and used “an encrypted messaging app to coordinate with each other that had auto-delete functions.”
Now, just shy of one year after the demonstration, we are witnessing the part of the government’s narrative in which the administration thinks it has won. Its position is clear, Menchaca said: “Not allowing the government to abuse people will cost you most of your natural life. Not allowing the police to murder an unarmed protester fleeing means your life is now forfeit to the state.”
But since the Prairieland defendants were indicted and as their trials wound on, we’ve seen many of the government’s attempts to charge people for disrupting ICE operations fall apart, some in now high-profile scandals such as that involving the former Broadview Six, a group of demonstrators at an ICE facility near Chicago, who were indicted on charges of conspiracy to impede a federal agent. (The charges were dropped after prosecutorial misconduct came to light.) Still, such failures have not slowed the government down. Last week, 15 people in Minnesota were indicted on federal conspiracy charges related to allegedly impeding federal officers.
The lesson here is not that the Prairieland defendants did something uniquely dangerous, but that they faced the same political repression any number of us could. The government, Menchaca said, is “trying to set the stage to criminalize every person who doesn’t agree to their atrocities. And our loved ones are suffering for their compassion.”
The Public Table
It was rumored to have been made from the tree
Of the first spinning place. Some said the side
Of a Spanish slaver spit from the sea.
Others church bench, chunk of stage, courthouse wall.
A widow swore her grandfather had helped
Drag it from his swamped fields after a storm.
One leg longer than the others, it leaned
Left. It belonged to no one and was ours.
Years pressed down on it with tobacco ash, peach
Pits, coffee rings, the impress of elbows,
A knife-mark widened by a thousand thumbs.
You can’t run your hand across the surface
Without passing through three or four fables
And a splinter that always finds the hand.
Such a common thing in an uncommon
World: this table, so worn down that it shines.
There’s room here. There’s never any room here.
It’s hard to keep clean. We all eat off it.
The Supreme Court’s War on Congress
The Supreme Court decided two cases on Tuesday that, at least at first glance, have nothing to do with one another. One involves the People’s Republic of China, Silicon Valley, and the Judiciary Act of 1789. The other involves Louisiana prisons, Rastafarian spiritual beliefs, and contract law. In both cases, however, are two shared and recurring impulses from the court’s conservative majority: a nearly boundless contempt for Congress as an institution.
The first case, Cisco Systems v. Doe, involves a group of plaintiffs who claim that the Chinese government has persecuted them for their religious beliefs. They filed lawsuits against Cisco, a major U.S. tech company, alleging that the company sold surveillance software to the Chinese government that was later used to surveil, torture, and otherwise abuse them.
In theory, no federal law is any more “constitutional” than the other. But laws from the First Congress tend to be seen as indicative of how the Constitution’s Framers intended the government to function. Among the early laws they passed was the Alien Tort Statute, or ATS, which allows federal courts to hear “any civil action” against a foreign national for any “tort” that was “committed in violation of the law of nations or a treaty of the United States.”
Congress enacted the ATS as part of the Judiciary Act of 1789—the first federal law it enacted to structure the federal courts. Though it was only occasionally invoked in those courts until the 1980s, one might think that its founding-era pedigree might entitle it to a little more respect. Apparently not. The modern-day aversion to this longstanding law was on display in the 2004 case Sosa v. Alvarez-Machain, a complex case about whether a man arrested by federal agents on drug charges could sue a Mexican national for temporarily apprehending him.
In his majority opinion, Justice David Souter wrote that the ATS “was originally understood to be available to enforce a small number of international norms that a federal court could properly recognize as within the common law enforceable without further statutory authority.” Those norms included “offenses against ambassadors, violation of safe conducts, and piracy.” Accordingly, he rejected Sosa’s more novel claim against Alvarez-Machain.
Does this mean that only that “small number” of claims described by Souter could be pursued under the ATS? Souter said no. He left open the possibility that the high court might recognize future implied claims beyond the more traditional ones. Justice Antonin Scalia took the opposite approach. He wrote in a partially dissenting opinion that he disagreed with the majority’s “reservation of a discretionary power in the federal judiciary to create causes of action for the enforcement of international-law-based norms.”
Scalia argued that this approach would “amount to judicial lawmaking” that the federal courts are “neither authorized nor suited to perform.” Souter, on the other hand, took a more deferential approach to the framework that Congress had created in the ATS. He noted that Congress could correct the court’s work through its own legislative powers by amending the ATS itself or adding new constraints to it through separate legislation.
“While we agree with Justice Scalia to the point that we would welcome any congressional guidance in exercising jurisdiction with such obvious potential to affect foreign relations, nothing Congress has done is a reason for us to shut the door to the law of nations entirely,” Souter explained. “It is enough to say that Congress may do that at any time (explicitly, or implicitly by treaties or statutes that occupy the field) just as it may modify or cancel any judicial decision so far as it rests on recognizing an international norm as such.”
The court’s conservative majority was never satisfied with that ruling. In case after case over the past 20 years, the justices repeatedly narrowed the scope of ATS claims, including by ruling that it could not be used to sue foreign corporations and by holding that domestic corporations can’t be sued for “general corporate activity” linked to human-rights abuses. In Cisco, Justice Amy Coney Barrett finally transformed Scalia’s dissent in Sosa into the court’s new majority opinion.
“Since Sosa was decided, we have firmly committed to the view that judicially created causes of action offend the separation of powers in almost every circumstance,” Barrett wrote. “As a result, we have virtually eliminated the practice of fashioning them.” She finished the job by “clos[ing] the door that Sosa cracked to judicially created ATS liability.” The Supreme Court’s rulings on these matters are often described as “closing the courthouse door” on wronged plaintiffs, but rarely by the majority itself.
Justice Sonia Sotomayor, writing in dissent, chastised the majority for its transparent about-face. “The Court nonetheless closes the courthouse doors not just to [the plaintiffs], but to virtually every future litigant seeking redress for a violation of international law under the ATS,” she wrote. “It thus overrules Sosa, without even acknowledging that it is doing so. Today’s decision marks yet another low point in this Court’s esteem for its precedents.”
Okay, you might think, maybe that’s a defensible reading of an archaic founding-era law. Perhaps there is good reason not to lean so heavily on a 18th-century statute in novel contexts. So then, what happens when Congress does provide unambiguous guidance on how to sue someone? Landor v. Louisiana Department of Corrections shows that even this is not enough to satisfy the justices.
Again, it is worth tracing the history of the underlying law in question. In 1990, the Supreme Court held in Employment Division v. Smith that litigants could not invoke the First Amendment’s Free Exercise Clause to challenge what the court described as “neutral laws of general applicability,” meaning general laws that applied to all people with few or no exceptions. Congress and President Bill Clinton responded to the perceived curtailment of religious freedom by enacting the Religious Freedom Restoration Act, or RFRA.
RFRA originally required laws and policies that infringed on free-exercise grounds to meet the highest threshold of judicial scrutiny. In 1997, however, the Supreme Court ruled that Congress could not apply RFRA to actions by state and local governments for federalism reasons. In response, Congress enacted the Religious Land Use and Institutionalized Persons Act, or RLUIPA, in 2000 that sought to apply RFRA protections to the states on narrower grounds.
One of those contexts was state prison systems. Under RLUIPA, states that accept funds from Congress for their prisons must also allow private plaintiffs to file Free Exercise Clause lawsuits against them and (more importantly, in this particular case) their employees. This framework sought to place Congress’s goals on firmer constitutional footing—namely, Congress’s Spending Clause power—even though its overall impact would be more limited than at the federal level.
It would be hard to find a more clear-cut violation of the Free Exercise Clause than Damon Landor’s treatment by Louisiana correctional officials in 2020. Landor, a Rastafarian, grew out his hair into lengthy dreadlocks in keeping with the practices of his faith. Long hair is generally disallowed in prison systems for safety and hygiene reasons, but Landor had previously obtained exemptions on religious grounds.
When he was transferred to a new facility, Landor told the prison personnel that his hair was kept long for religious reasons. He also provided them with a copy of a 2017 ruling by the Fifth Circuit Court of Appeals, which has jurisdiction over Louisiana, that held that it would be a RLUIPA violation for state prison officials to cut a Rastafarian’s hair. Nonetheless, prison officials threw the ruling in the trash and shaved Landor’s head.
In response, Landor sued both the Louisiana Department of Corrections, or LDOC, as well as the guards themselves in their personal capacity under RLUIPA. The Fifth Circuit Court of Appeals had previously held that RLUIPA could not be used to sue prison officials in their personal capacity. In 2020, however, the Supreme Court ruled in Tanzin v. Tanvir that plaintiffs could bring those claims against federal officials under RFRA. Landor now sought to apply that reasoning to RLUIPA.
Justice Neil Gorsuch, writing for the court, declined to do so. He framed the dispute not as a question of religious freedom, but of Congress’s power to impose conditions on federal funds. The decision is an unusually muddled one for Gorsuch. He insisted that Congress’s choice to provide federal funds to Louisiana so long as the state abides by certain conditions is a contract of sorts. While Congress can impose conditions on those funds for the states, Gorsuch argued, it cannot contractually bind people—in this case, the prison officials—who didn’t consent to the agreement in the first place.
This reasoning is too clever by half. The Louisiana Department of Corrections is not some sort of cosmic entity or demiurge. It does not independently exist in a metaphysical sense despite its legal personality. It is, at its root, a group of people in buildings who sit behind desks and walk down hallways and occasionally violate people’s constitutional rights. Gorsuch nonetheless hypothesized about ways that Congress could, in theory, rewrite the law to properly bind those employees in a private capacity.
“For example, Congress could have said that, as a condition of federal funding to LDOC, its officers had to agree to enter separate contracts with the federal government consenting to answer suits under RLUIPA,” he wrote. The officers arguably fulfilled that condition by agreeing to work at the Louisiana Department of Corrections in the first place, which is supposedly still bound by RLUIPA’s conditions.
Justice Ketanji Brown Jackson, who dissented with the court’s other two liberal members, also argued that the majority’s reading of the Spending Clause upended decades of precedent about congressional powers. “Today’s decision magically transforms a federal statute into an invitation to be accepted or declined, deemed binding only if each particular defendant has explicitly agreed to be penalized,” she explained. “No matter that laws, as opposed to contracts, don’t ordinarily work this way.”
At the root of Gorsuch’s opinion, she hinted, was a fundamental lack of respect for Congress as an institution. “In the end, the Court reduces some of Congress’s greatest legislative achievements—federal laws that secure civil rights, environmental stability, healthcare, and more—to nothing more than the wheelings-and-dealings of an especially wealthy private party,” she warned.
Gorsuch did not forthrightly address the Tanzin argument, apparently because his reductive Spending Clause interpretation made it unnecessary to grapple with. Nonetheless, Jackson argued that Tanzin’s reasoning applied with “even more force” to RLUIPA because damages would often be the “only form of relief available” to prisoners when their religious freedoms are violated.
“The Prison Litigation Reform Act’s exhaustion requirement and strict limitations on injunctive relief in prisons, coupled with States’ ability to transfer prisoners and thereby moot claims for injunctive relief, mean that withholding a damages remedy will often leave prisoners with no remedy at all,” she explained. A right with no remedy, it goes without saying, is not really a right at all.
For most of the 20th century, the Supreme Court confined itself to interpreting federal law instead of rewriting it. Thanks to the conservative legal movement, that posture has changed. The court’s Republican appointees have developed a wide array of tools to second-guess Congress, sometimes even under the cynical guise of defending its prerogatives.
Under the major-questions doctrine, for example, the Supreme Court has claimed the power to strike down federal rules and regulations if the statute they rely upon does not “speak clearly” on the issue in question. What is often framed by the conservatives justices as a check on executive-branch overreach is actually a curtailment of Congress’s legislative powers. By denying it the power to pass broadly worded legislation, the court is denying it the ability to legislate for unforeseen circumstances.
The justices are also either ignorant of, or hostile to, the basic nature of the legislative process. Congress typically enacts legislation after a long period of debate, consideration, and jockeying between various factions—from groups and movements that can be partisan, civic, business, special-interest, activist, and so on. Entire election cycles can hinge on a specific bill, as the 2010 and 2012 elections did for the Affordable Care Act.
This democratic process receives no deference or validation from the high court, either implicitly or explicitly. Thus, the work of years of activism, negotiation, and compromise can be undone with a few friend-of-the-court briefs and the right five justices on the court. When the Supreme Court struck down the Voting Rights Act’s preclearance formula in 2013, it invited Congress to simply draft a new one—knowing full well that congressional Republicans would never agree to it.
When the justices don’t want to overturn a law, they simply rewrite it. In VRA decisions in 2021 and earlier this year, the court’s conservatives added atextual limits on the law’s protections under the guise of interpreting it. Baseless fears of voter fraud can be used by states to evade challenges to voting restrictions; states’ rights to partisan gerrymander can be used to defeat racial-gerrymandering lawsuits. Thirteen years later after Shelby County v. Holder, with the rest of the VRA now in ruins, it is clear that the court wouldn’t have approved a new preclearance formula anyway—it wouldn’t have mattered how “clearly” Congress managed to speak on the matter.
“Heads I win, tails you lose,” has become this court’s judicial maxim. Tuesday’s rulings underscore how far these impulses will go. It does not matter if Congress broadly intends for courts to hear civil lawsuits over human-rights violations. Nor does it matter if Congress narrowly seeks to ensure that Americans whose federal constitutional rights are violated via federal funds can seek redress in federal court. Whatever Congress does, the Supreme Court will happily insert its own judgment in favor of that of the people’s elected representatives.
Democratic Socialists Are Winning Over Black Voters
In the past, conventional wisdom would have us believe that any victory by the Democratic Socialists of America was due to their overwhelmingly white, young, transplant membership—bike lane users, co-op members, and Bernie 2020 voters. Meanwhile, DSA candidates struggled with working-class Black and brown voters due to a lack of trust, gentrification-fueled disdain, and communication failures. And more than anything, socialism just wasn’t something Black and brown people were “comfortable” with historically.
But recent election victories have thrown out that entire narrative. Nowhere was that more evident than in Washington, D.C., last week, where the DSA-backed mayoral candidate won the Democratic primary thanks to support in majority-Black neighborhoods, while the candidate packaged as the preference for native Black voters actually lost them by a landslide.
In the weeks leading up to the primary, moderate Democratic Councilman Kenyan McDuffie framed himself as a measured, natural progression from current Mayor Muriel Bowser. He promised to be tough on crime and focused his rhetoric on the native residents of D.C.’s historically Black neighborhoods. Meanwhile, Councilwoman and Metro DSA member Janeese Lewis George represented a progressive vision for the city that focused on universal childcare, housing, and affordability—a vision that political commentators and media outlets said was more salient with the transplant-heavy neighborhoods.
The New York Times wrote that Lewis George was “expected to be preferred by younger white residents who’ve lived in Washington less than 10 years.” CityCast DC featured a “Newbies Vs. Natives” analysis stating that “the Democratic Socialists of America member Lewis George does not seem to be cleaning up among D.C.’s poorer and less-educated voters,” and that “the younger, better educated, and newer you are to D.C., the more likely you are to support Lewis George.”
Lewis George’s primary victory put that narrative to rest. She won seven of the eight wards in D.C. and had secured more than 50 percent of the vote even before the first round of ranked-choice tabulation.
McDuffie only won Ward 3—which contains affluent, majority-white neighborhoods like Woodley Park, Chevy Chase, Foxhall Village, Friendship Heights, Palisades, and Tenleytown. Ward 3 is 69 percent white, with nearly 90 percent of residents holding a bachelor’s degree, an average age of 40 years old, and a median household income of around $144,877. And yet this younger, white, more educated, more affluent ward is the only one that went for McDuffie, and just barely. NBC reported that the specific neighborhoods that went for him were “among the most heavily white neighborhoods in D.C.”
Conventional wisdom would have had McDuffie cleaning up in DC’s Ward 8—81 percent Black with an average household income of $52,769 and less than a third of its residents holding a bachelor’s degree. Lewis George won it by 15 points. And in Ward 5, which is 55 percent Black and where McDuffie grew up, George won by 20 points. In the end, it was McDuffie who found the most support in the city’s whitest neighborhoods, while Lewis George overwhelmingly carried Black and Latino ones.
There are plenty of theories as to why McDuffie lost so handily both across D.C. and specifically in poor neighborhoods of color. His focus on crime—calling Lewis George’s decision to vote against a teen curfew a “failure” after a chaotic teen brawl in Navy Yard—may have been overshadowed by a more imaginative platform from Lewis George, who was trying to address the constant struggles that the district’s most vulnerable residents face. Hyperfocusing on teen crime—an issue that Lewis George will eventually have to address—may not have landed well while hundreds of National Guardsmen roam the streets of D.C. at the behest of the president. His ties to Bowser (who has a dismal 49 percent disapproval rate) and the city’s centrist political establishment didn’t help either, as the outgoing mayor gave him her support without offering an official endorsement.
It’s easy to make comparisons between Lewis George and New York City Mayor Zohran Mamdani. Two DSA members ended long reigns of neoliberalism in two major East Coast cities, and expanded their voting blocs well into the Black and brown working class even as pundits expected them to be successful only in “commie corridor” neighborhoods from Bushwick to Mt. Pleasant. But there are notable differences. Lewis George never got a Bernie Sanders or AOC endorsement. Lewis George stated that she has no relationship with Mamdani. And D.C. operates in a different landscape given its lack of statehood—another unique issue Lewis George will face as she likely squares off with President Donald Trump, who has had no qualms about strong-arming D.C. leaders.
Lewis George will certainly face a host of doubts and challenges in her tenure, as will DSA as a whole. Of course this movement would be nowhere without the college educated, mostly white transplants that move to cities like New York and D.C. But it’s equally true that they have made legitimate connections with older, more moderate natives that are skeptical of them. That tension will remain. But Lewis George’s victory—bucking stereotypes and punditry to deliver a resounding, mandate-securing election—shows that democratic socialism can no longer be viewed as a disqualifier for Black working-class voters. It’s mainstream now.
Trump’s Algae Problem Is a Lot Bigger Than the Reflecting Pool
Donald Trump dreamed of turning the Lincoln Reflecting Pool “American Flag Blue” in advance of celebrations for America’s 250th anniversary on July 4. Instead, he got a pungent, bright green embarrassment. National Parks employees have yet to fully remove the algal bloom that sprang up after Trump’s ill-fated paint job, despite applying vacuums, hydrogen peroxide, and nanobubbles to the problem; the next step will be to drain the now-swampy basin for the second time this month and restore the blue sealant that has been floating to the surface in unsightly chunks. The Washington Post reported on Tuesday that Washington D.C.’s Department of Energy and the Environment was conducting an investigation into what killed the multiple ducks that have been found dead in the pool’s waters.
It’s all a bit too on the nose. The tacky $16.4 million vanity project was carried out in part by giving a $1.7 million no-bid contract to a firm called (appropriately enough) Greenwater Services, which is owned by an already scandal-laden Trump loyalist, John J. Cafaro. On June 15, workers reported that one or two of the four algae-killing machines Greenwater used weren’t working at any given time. Trump has—without evidence—blamed the algae problem on “vandals,” alleging that anonymous hoodlums sabotaged the pool with knives and fertilizer; this does not seem to be true. Still, as of June 24, the Parks Police, National Guard, and U.S. Marshals have been patrolling the usually placid site. As of Tuesday, six arrests had been made. White House spokeswoman Karoline Leavitt claimed—also without evidence—that those detained included “longtime donors to the Democrat Party, to Barack Obama, to ActBlue.” Newly installed fencing around the pool is apparently meant to deter what Interior Department spokeswoman Katie Martin has called an “increase in vandalism by leftist activists.” Trump pledged to drain the metaphorical swamp. Instead, he’s created one.
Algae, however, are much more than either smelly sludge or a tidy narrative device. While algae play several critical roles in freshwater and saltwater ecosystems, algal blooms like the one now bedeviling the Reflecting Pool are “a growing problem,” said marine biologist Gregory Dick. He’s the director of the Cooperative Institute for Great Lakes Research, or CIGLR, a partnership between the University of Michigan and the National Oceanic and Atmospheric Administration, or NOAA. “They’re becoming more frequent as water pollution becomes more of an issue, and they grow more in warming condition,” he explained. “The Reflecting Pool is not an exception.”
The government’s newfound war on algae contrasts starkly with its repeated attempts to defund the experts who protect the public against harmful algal blooms not appearing on Washington, D.C., landmarks. The Trump administration’s cuts to research funding and federal agencies like NOAA have already undermined the federal government’s essential role in monitoring, responding to, and understanding harmful algal blooms. Deeper cuts outlined in next year’s federal budget would lower the public’s defenses against those blooms just as climate change helps them proliferate.
Trump’s talk of vandals and knives notwithstanding, you don’t need conspiracy theories to explain how algal blooms happen. Experts suspect that the Reflecting Pool algal bloom began as a cyanobacteria, or blue-green algae. Those generally grow thanks to abundant nutrients like phosphorus and nitrogen, warm temperatures, and calm waters. “The Reflecting Pool has those three ingredients,” Dick said. There’s no official definition for what constitutes a harmful algal bloom, and the one in the Reflecting Pool hasn’t received that designation. But they tend to give off a foul smell and are known to kill birds. Cyanobacteria produce a toxin called microcystin that can fatally poison animals and cause nausea, vomiting, and skin rashes in humans. A 2014 microcystin outbreak in Lake Erie left nearly half a million people in the greater Toledo area without running water for three days.
An enormous amount of local, state, and federal resources are needed to keep the country’s waterways safe. NOAA’s Great Lakes Environmental Research Lab—which houses CIGLR—monitors and responds to algal blooms throughout the Great Lakes watershed, including Lake Erie. Researchers there use a range of technologies to keep tabs on algae in real time. Remote sensors let them track the distribution of harmful algal blooms. Buoys and remotely operated vehicles measure nutrient levels in the water, and scientists analyze physical samples to understand which species of algae are present at any given time and what environmental conditions cause them to give off certain toxins. If the scientists spot a potential threat, NOAA alerts municipal water treatment plants so that they can proactively safeguard the water sources that some 40 million people use to hydrate, cook, and shower. Algal blooms pose dangers not only to public and environmental health but to local economies that rely on revenue from tourism and fishing operations, which depend on the Great Lakes Lab to help determine when beaches should be closed down and which fish are safe to catch and sell.
In spite of its crucial role in monitoring blooms, the lab lost roughly 40 percent of its staff last year. That was thanks to cuts imposed by the Department of Government Efficiency, which laid off newly hired and promoted staff and encourged federal employees to accept buyouts and retire early. The lab still hasn’t received all of the funds it was appropriated by Congress. The White House’s proposed budget for Fiscal Year 2027 also includes an 18 percent cut to NOAA’s overall budget; it would completely eliminate funds for “Ocean, Coastal and Great Lakes Research.” Funding for the Cooperative Institute for Marine and Atmospheric Studies—the technical backbone of the National Hurricane Center, which houses researchers that forecast harmful algal blooms—is also at risk.
Thankfully, these sorts of proposals tend to be aspirational. The budget Congress passed last year avoided the steepest cuts to NOAA outlined in the White House’s FY2026. So far, Project 2025’s authors in the Trump administration have not been able to follow through on their pledge to dismantle and privatize the agency. But those funds remain under constant threat. What was already a bare-bones team at the Great Lakes Environmental Lab, or GLERL, pre-DOGE has had to make do with a lot less.
The reduced funding has already had some very concrete effects. Some of the Lab’s autonomous sample processors—which collect samples and measure water quality—“did not go out last year because of funding delays and lack of personnel,” Dick said. “Reduction in support and capacity for places like GLERL would have big impacts on boots-on-the-ground operations” he added, endangering researchers’ ability to provide up-to-date measurements and forecasting to (among many others) beach managers, drinking-water treatment facilities, and charter boat fishing captains.
Dick worries too that continued cuts will hamper researchers’ ability to understand how algal blooms are responding to rising temperatures and climate-fueled extreme weather. Cyanobacteria thrive in warmer temperatures. Heavy storms can wash their favorite nutrients into the water, fueling algal growth. Lake Superior, for instance, was long thought to be “the coldest and cleanest of all the Great Lakes,” Dick said. In the 2010s, it suddenly started seeing substantial algal blooms, following a series of 500-year storms that washed off nutrients from the landscape. Lake Superior is also among the fastest-warming lakes on earth; over the past 30 years, summer surface water temperatures have increased by five degrees.
Unlike Lake Superior, the Reflecting Pool has long hosted algae. As Washington’s summers become increasingly swamplike, eliminating the algae altogether may well prove impossible. As it has stretched out over the last several weeks, the Reflecting Pool debacle has been something of a microcosm for Trumpist governance, combining handouts to inexperienced loyalists with gaudy kitsch and baseless accusations against the left. It is also about as good a summary as any for the right’s approach to a climate crisis that’s fueling harmful algal blooms the world over: When it becomes impossible to keep denying a problem you helped cause, blame it on your political enemies and try to throw them in jail.
August
In one corner above a field: a kid’s drawing of the sun. But with fat, round rays, like yellow petals, and a smiling lion’s face—cleft lip attached to a pink, upside-down triangle nose; black ovals for eyes. Something in me has awoken. A spark. A love. A sensation, by definition, must be felt. And then die off. No one still talks about the dentist who killed the lion named Cecil. I shut that in a box, along with learning that cats wounded in the wild don’t heal—that they die without the strength to hunt. I don’t understand much. Not suffering. Not the nature of risk. My fears—captive, domestic—yawn and flex their feet. Another version of me was sixteen and drove a yellow truck named Frisky. She drank with her friends beneath the shade of a tree. She could let her thoughts out. But she never put them down.
Grave Error
You were always funnier than most, so I’m waiting
for this joke to land. When I hear the phrase “grave
error,” I think of you being lifted out of the ground
& your mother loving you better. I think of your
tombstone hitting your stepdad over the head.
Grave error: the words slipping from their mouths
as your skin turns back elastic, as flesh reattaches
to your bones. Old friend, it’s been 10 years.
Grief would be easier if you were dead. Instead,
our songs, your voice, the sticky dampness
of your skin is vivid enough in my mind that I
can make a reader see you like I did. They can
feel the goose bumps forming on my skin as you
lifted me up out of my misery. I still see things
& go “damn, he would love this.” I still expect you
to come across some corner while I’m walking
& tell me it was all a grave error. You’ve been alive
this whole time. The poet wants their words back
like I want you to connect the setup to the punch line,
tell me why I’ve been sleeping with a corpse.
They Fought Their Abusers. They Were Imprisoned for It.
In 2019, I began a large-scale reporting project: I sent out surveys to 10,000 people incarcerated in the United States in women’s prisons on murder or manslaughter charges. I was trying to understand the scale of “criminalized survival,” as it’s been termed: wherein a person—almost always a woman or girl—is arrested, prosecuted, and incarcerated for actions she took to protect herself or a loved one from physical or sexual violence. I received more than 1,000 replies. I found that at minimum, 30 percent of my respondents were criminalized survivors, and I knew I had to write a book. I would interweave my survey findings with three deeply reported stories of individual survivors. Early on, I settled on two women as my subjects, but I hadn’t found a third. Then, a few years into the project, I came upon TC Brooks’s letter. She wrote that she was serving 25 years to life for killing her stepfather after “abuse, more abuse.” She had spent most of her time in prison working to heal and help others. TC included a booklet she had created to educate prisoners about domestic and sexual violence. She’d signed the cover: “Caged no longer on the inside, I sing a song of rebirth. Free from the inside.” Immediately, I began trying to get in touch with TC. Her story was remarkable. She would soon become the third subject of Unreasonable Women.
On July 10, 2019, TC sat before the parole board for the fifth time. She compared the process to being a human roulette ball; she’d been trying to stop the wheel for decades, but it kept spinning. And she kept bouncing around, hoping for some good fortune to strike.
The hearing was overseen by Kevin Chappell, a Department of Corrections career man who had been working for the prisons even longer than TC had been inside them. He had risen in the ranks from guard to lieutenant to administrator to deputy warden, employed in men’s facilities across the state, from Folsom to San Quentin.
TC once again detailed the extensive sexual abuse she had endured, the abuse that led to her murder conviction, and she recounted her fear of being subject to scrutiny and doubt. She once again vowed rehabilitation and accountability, once again unpacked her traumatic past, a past that she had held deep shame about for so long, before a group of imposing strangers.
Chappell wanted to know why TC hadn’t been able to prevent her own rape on the night of her crime. He wanted to know why she hadn’t spoken up sooner about the sexual abuse she had experienced. She wished she could tell him the truth: ’Cause I didn’t wanna be in a room like this, sitting in a chair like this, talking to a man like you.
After two hours, the board broke to deliberate. When they returned 20 minutes later, they told TC and Lilli Paratore, a staff attorney at a legal nonprofit, that they would, in a rare continuance, need additional time to make their decision. They needed to investigate TC’s “violence risk.”
On December 6, 2019, TC and Paratore returned to the parole hearing room at the prison. Commissioner Chappell told TC that while they had taken her youth into account, they could not consider the abuse a mitigating factor.
“We found no information to corroborate your claims of the severe sexual or physical assault at the hands of the victim,” he said. TC still posed “an unreasonable risk to public safety.” She’d be heading back to the California California Women’s Facility. There, he continued, she should focus on creating “healthy boundaries in regards to your relationship with your mom.… I think you’ll learn a lot about yourself in that regard.” She could apply for parole again in a few years. He wished her luck.
TC was accustomed to parole denials, but she was crushed that the commissioner had doubted her about the abuse. “It took so many years and so much courage to face those demons,” she said. “How dare he?”
When Chappell spoke to her, she had been hot with anger, but she had to suppress it. If they saw a hint of fury, she was never, ever getting out. Paratore also presented as calm, though she had internally gone, she told me, to “a place of rage.” She spent weeks writing informal appeals late into the night, arguing that the board had revictimized TC. The questions Chappell had asked, Paratore believed, “reveal a disturbing lack of understanding by the panel about the dynamics of power and control in abusive relationships and how fear, shame, and embarrassment prevent survivors from coming forward about their experiences.”
A month later, in January 2020, TC and Paratore reconvened. They decided that parole wasn’t happening. “Unless her story changed significantly and she just lied,” Paratore told me. “Which, you know, I can’t counsel a client to do.”
Paratore wondered: Maybe there was a different route, one she hadn’t quite put her finger on. She discussed it with her colleagues. Nancy Lemon, the domestic violence expert and law professor, had remained invested in TC’s case. Lemon knew Nancy O’Malley, the elected district attorney in Alameda County, a woman whose predecessor had successfully tried TC.
The D.A.’s office, no matter who led it, had always opposed parole, which was typical for prosecutors. But a new law had recently come into effect in California, allowing a D.A. to support a resentencing for someone who may not have had a fair trial outcome. Lemon and Paratore thought that if O’Malley got to know TC’s case, her office might suggest a new sentence to a judge, who in turn could hand TC a sentence that would mean she’d served her time.
O’Malley met with Lemon and Paratore but made it clear that she didn’t want to be involved in resentencing. In Paratore’s interpretation, it was a political gamble: Were TC to reoffend, the D.A. didn’t want to be linked to letting her out. However, in a highly unusual move, Paratore told me, O’Malley said that if TC requested a commutation from the governor, asking that her sentence be shortened, she would back the request.
Paratore began to immediately compile a packet to be sent to Governor Gavin Newsom. As promised, O’Malley wrote a letter of support for TC. She asked that TC not be allowed to live with her mother, since the relationship was problematic. Otherwise, she wrote, “as all parties are seeking the outcome in the name of justice, I hope to see Ms. Brooks released soon.”
Newsom had a clear path to letting TC go. The same D.A. who had always opposed release now endorsed it. There were no roadblocks for the governor.
In January 2021, Paratore submitted TC’s packet.
On March 12, the Central California Women’s Facility was still under Covid lockdown. Nobody was allowed out of their pods except for critical workers, like laundry or kitchen employees.
“Brooks, open your door,” an officer said over the intercom.
TC poked her head out.
“Put on your states. You’re going to B Yard.”
“The Cop Shop” in B Yard was a building where the warden took calls, and where, as far as the prisoners could tell, the rest of the guards sat around all day, eating food from large tubs they’d brought in from home. It was also where the phone conferences were held.
TC sped across the grounds.
“Where you going, Brooks?” an officer asked.
“Gotta go to Bravo yard,” she said. “To the program office.”
“What for?”
“I’m goin’ home.”
“You sure?”
“I’m pretty sure.”
She approached the Cop Shop and took a seat on a bench. A few prisoners filed in and out of a room. Then it was her turn.
The warden was waiting. She stood before him.
“Brooks?”
“Yes, sir.”
“What’s your number?”
“W45882.”
“You know why you’re here?”
“I believe I do. Am I gonna get a phone call?”
“You are. Do you know who’s gonna call you?”
“The governor’s office.”
The warden looked her over and leaned back. “What do you think of your stay here?” he asked.
“It was a long haul,” TC said diplomatically. “I’ve learned a lot.”
“I read your file,” the warden said. “The past got you here. And I am sorry about your past.”
The phone rang. The warden answered and then handed the phone to TC.
A woman was calling on behalf of Governor Newsom. She had the pleasure and privilege, she told TC, of informing her that Newsom had signed her commutation paperwork. He agreed that she deserved a second chance. TC was ordered for immediate release, within the week. Was there anything she wished to say to Mr. Newsom, the woman asked.
“Tell him I appreciate the second chance, and he will not regret this decision,” TC said. “I promise him, I’m gonna be a feel-good story he can tell.”
She headed back to her cell. She needed to concentrate on getting her affairs in order. She had been confined for 31 years.
She had seven days to go.
From the book Unreasonable Women: Three Stories of Violence, Imprisonment, and Extraordinary Survival, by Justine van der Leun. Copyright © 2026 by Justine van der Leun. Reprinted by permission of Ecco, an imprint of HarperCollins Publishers.
Trump 250 Gala Takes Humiliating New Turn as More States Pull Out
Pennsylvania Governor Josh Shapiro occupies something of an intriguing position among Democrats. He represents a state that Donald Trump won twice—a state that’s both deeply divided and pivotal in deciding presidential elections. Yet Shapiro also consistently garners high approval ratings there, and polls regularly show he enjoys the support of around one quarter of Republicans. On top of all that, he manages this while remaining sharply critical of Trump—and without pandering to MAGA voters.
Case in point: In an interview with me, Shapiro confirmed for the first time that Pennsylvania will not participate in Trump’s big planned gala celebrating the country’s 250th anniversary on the National Mall. The way Shapiro is addressing this decision deserves notice. It shows that it’s possible for a Democrat to sustain enduring public support in a swing state—including nontrivial backing among voters who helped elect Trump—while casting Trumpism, appropriately, as an overwhelmingly destructive force in American life.
“This president routinely makes patriotism partisan and personal—and it shouldn’t be that way,” Shapiro told me, referring to Pennsylvania’s decision not to join the so-called Great American State Fair, which Trump has described as “the most spectacular TRUMP RALLY of them all.”
Shapiro said his office had canvassed opinion among many Pennsylvania businesses about Trump’s gala. Shapiro’s aides enlisted the help of the Pennsylvania Chamber of Commerce, which communicated with companies across the state, small and large alike, about whether to join the coming festivities.
“None were interested,” Shapiro said. “It reflects this sad state of affairs that we find ourselves in—that the president has politicized this to a degree that businesses don’t want to participate.”
Pennsylvania’s decision is significant, given that Trump’s flipping of the traditional “Blue Wall” state was pivotal to his 2016 and 2024 victories. Its deliberations over Trump’s fair had been closely held. The New York Times recently reported that Pennsylvania was “known to” be pulling out, based on unclear sourcing and with no confirmation. By contrast, CNN and NOTUS reported that the state was undecided.
But Shapiro confirmed to The New Republic that the decision to withdraw is now official. In joining eight other states that appear to be pulling out (Oregon, Washington, Massachusetts, Illinois, Connecticut, Maine, Rhode Island, and North Carolina), Pennsylvania becomes the first swing state that has flipped between the parties in recent presidential races to do so.
Coming after many musical artists have declined to participate, it’s another sign of how badly Trump—and his approach to this hallowed national anniversary—have alienated the middle of the country. Trump’s treatment of this moment as akin to a monarchical festival is of a piece with his ballroom, his triumphal arch, and other efforts to transform the nation’s capital into something more like a czar’s imperial court. It’s giving Democrats like Shapiro an opening to decline to participate in the president’s Bonapartist self-glorification while giving voice to a disinterested, public-spirited patriotism more in sync with the virtues of republican governance.
“We don’t celebrate one individual,” Shapiro told me. “We celebrate ‘we, the people.’ Unfortunately, the president doesn’t seem to get that. He wants to make it all about himself. What’s clear is that’s not where the American people are.”
When Shapiro was first elected governor in 2022, he made big inroads with rural, Trump-backing Pennsylvanians. Though data on this is sporadic, he’s managed to hold on to the support of around a quarter of Republican voters through late 2025 and early 2026. He holds a wide lead over his MAGA opponent in his campaign for reelection this year.
What’s notable is that Shapiro has done this without pulling punches in his criticism of Trump. Shapiro hasn’t proceeded as if the 2024 election revealed Trump as a tribune of the people who mystically identified a deep strain of right-wing populist nationalism in the American psyche. Some (though hardly all) Democrats reacted that way, leading them to trim their ideological sails, stick to kitchen table issues, and treat immigration as a largely lost debate while seeing engagement with Trump’s ethnonationalist and authoritarian abuses as a distraction from the route back to relevance.
Shapiro, for his part, has forcefully opposed Immigration and Customs Enforcement’s plans for vast detention camps in central Pennsylvania. And while some immigration activists would like him to go still further in this regard, Shapiro has reinforced prohibitions against state law enforcement asking for people’s immigration status or participating in enforcing federal immigration law.
In a sense, Shapiro gives something to different elements of the Democratic coalition. Democrats who favor an “abundance agenda” cite Shapiro as a model, in that he stresses removing bureaucratic constraints to unshackle effective government and deliver concrete economic results. Yet Shapiro doesn’t treat “deliverism,” as this form of politics is sometimes called, as sufficient in itself. He’s also willing to defend immigrants while engaging ideologically with the rank ethnonationalism—and even the Christian nationalism—driving Trump’s efforts at mass violent removals.
“We now have a president who tries to bring us to the lowest common denominator every single day, who attacks people who don’t vote like him, or look like him, or pray like him,” Shapiro said.
And at a time when Democrats are debating how to win back Trump-supporting working-class voters, Shapiro says the answer is to bluntly inform them that Trump’s policies are, well, shafting them royally. He highlights the tens of thousands of Pennsylvanians who, his office says, have been at risk of losing food stamp benefits and the more than 100,000 at risk of losing health care access. He also points to the 300,000 people who could lose Medicaid coverage next year.
“More than half of the people losing health care and food assistance come from counties that Trump won,” Shapiro told me. “He screwed over the very people that put him in the White House. He turned his back on them, and he lied to them.”
Shapiro suggests that Democrats can go right into these communities and make this case to Trump voters, as he does. “I don’t rub it in their face by any stretch that their choice for president has made their lives worse,” he continued, stressing that his posture is always one of “fighting every day to make their lives better.”
Asked if the decision not to participate in Trump’s gala is rooted in a rejection of Trumpism, Shapiro said it’s not. He noted that the lack of interest of businesses drove the decision, and said joining the gala would have required the state to shell out $700,000 in taxpayer money, which will instead fund celebrations throughout the state.
Still, one can discern a through line linking all of this. It’s that winning the middle of the country is fully compatible with a full-throated indictment of Trump and Trumpism as truly toxic forces in American life. The ethnonationalist cruelties, the endless corruption and self-dealing, the massive upward transfer of oligarchic wealth, the displays of dictatorial self-glorification, the desecration of hallowed republican symbols in the nation’s capital—most ordinary people just want to be done with Trumpism and all its enmities and degradations already.
“I think people are exhausted by his chaos, his cruelty, and his corruption—and they’re seeking something better,” Shapiro said. He looks at all the ordinary Pennsylvanians coming together across social and ethnic lines at events commemorating our 250th anniversary across the state, all motivated by simple, selfless patriotism, and he concludes: “We are better as Americans than the negativity that Trump injects into our lives.”
If this approach can secure solid majority support in must-win Pennsylvania, that seems like something Democrats can learn from.
Cellebrite said it cut off Russia, but Russia used is tools anyway
California extended a lifeline to some of its aging mobile home parks. What happened next?
This story was originally published by CalMatters. Sign up for its newsletters.
The roads used to flood at Shady Lane Estates whenever it rained.
Water pooled on the mostly-dirt roads that ran through the mobile home park, combining with the waste of constantly backed-up septic tanks. Early on those wet mornings, parents would pack their kids into cars and ferry them through the noxious slurry to the front gate to catch the school bus.
Summer days weren’t much better.
Afternoon temperatures regularly exceed 110 degrees in unincorporated Coachella Valley. The park’s antique electrical system regularly failed, knocking out AC units and turning the decades-old, poorly-insulated mobile homes into family-sized kilns. Rubi Castro, a mother of four, remembers placing her small children in large buckets of cold water until the power lurched back on.
That chapter of the park’s history came to a celebrated end in late April when it reopened, renewed.
Funded partly through a state program aimed at rehabilitating California’s aging mobile home parks, Shady Lane’s robust new electrical system can now endure the draw of dozens of air conditioners. Pipes connect the park to the local water and sewer utilities. The roads are paved, there’s a shaded playground for kids and each of the 32 old mobile homes has been replaced with new, built-to-last units — plus eight more, to boot.
Castro, speaking on June a day that topped out at 113, said it’s been warm out since she moved back in April. But she’s comfortable in her new home where, she said proudly, “it feels like we live in winter.”
She “can’t wait to experience the rain.”
A dirt road in the Shady Lane Estates Mobile Home Park in Thermal in 2023. The community has since been renovated through a state program. Credit: Pablo Unzueta for CalMatters
A two-bedroom, two-bath dwelling is one of 40 new manufactured homes serving more than 140 residents at Shady Lane Estates Mobile Home Park in Thermal. Credit: Alex Tapia
The glow-up of Shady Lane under the ownership of the nonprofit Caritas Corporation comes courtesy of another dramatic overhaul inside California’s housing department.
Back in 2023, as CalMatters reported, a state program designed to throw a financial lifeline to dilapidated mobile home parks had gone largely unused and forgotten for at least a decade thanks to a labyrinthine application process and a focus too narrow to help most applicants.
That year it was stripped down to its studs, rebuilt and renamed the Manufactured Housing Opportunity and Revitalization (MORE) program.
Along with funding from Riverside County and the city of Coachella, the Shady Lane overhaul received $10.6 million, one of 28 parks to receive an award and the first rehab project to be completed. Another 19 have broken ground, according to the state housing department.
For a state facing a crippling housing affordability crisis and an affordable housing financing system often characterized as sclerotic and costly, the transformation is a rare bit of unquestionably good news.
But the short history of the program also underlines just how challenging it is to maintain and rehabilitate old mobile home parks, a largely overlooked source of the state’s scant low-cost housing stock.
California is home to 4,635 mobile home parks, according to the state housing department. Together they provide space for nearly half a million units. Most are owner-occupied. They’re also significantly cheaper than comparably sized single-family homes or townhouses, making them one of the few homeownership opportunities that is even plausibly affordable to Californians with lower incomes.
“While it’s not as shiny or flashy as a big beautiful new rental apartment, it’s a vital source of affordable housing,” said Betsy McGovern-Garcia, vice president of Self-Help Enterprises, an affordable housing developer in the San Joaquin Valley which manages two parks.
Even after receiving state funding through the MORE program, some projects are still mired in permitting delays or have been scaled back for lack of funding. And despite awarding nearly $140 million to more than two dozen parks that hold more than 1,000 mobile homes, housing advocates say that likely covers just a small fraction of the need.
No more money is on the horizon.
A new program for old parksThe program emerged from the bureaucratic makeover of a 1980s state loan initiative called the Mobile Home Resident Ownership Program. As implied by the name, it was initially focused on helping California’s mobile home owners — who typically own their units, but not the land on which they sit — to buy their parks and run them as resident-owned cooperatives. Later, that narrow purpose was expanded to fund park purchases by nonprofits and local governments.
After an initial wave of acquisitions early on, the program fell into disuse. Between 2013 and 2023, it awarded only a single loan, despite having tens of millions of dollars in the bank.
The 2023 overhaul expanded the program to serve a separate, pressing concern: The sorry state of many of California’s mobile home parks. Funds could now be used not just to fund purchases, but to repair and replace park infrastructure and even the dilapidated units themselves. Private owners could apply. The application was simplified and the terms made much more generous such that many of the loans might ultimately be forgiven.
To top it off, lawmakers threw in an additional $200 million through two one-off budget bills.
“It’s more responsive to the range of challenges that park residents and park owners are seeing,” said Brian Augusta, a housing policy lobbyist who advocated for the change. Case in point: Roughly two-thirds of the funds awarded through the program went to repair and rehabilitation projects.
An empty mobile home lot in Stockton Park Village in Stockton in January 2023. Credit: Miguel Gutierrez Jr., CalMatters
The Caritas Corporation was the one organization to receive funding through the older version of the program in the preceding decade. Officials at the state housing department encouraged the nonprofit to give the money back and reapply for more funding through the new one.
“It’s a great program, much easier,” said Tracy Bejotte, chief operating officer at Caritas. “They really got their act together.”
The proof, she said, is Shady Lane.
“It used to be a rough, tough place,” said Joel Beltran, a produce vendor at a local shop, who lives at the park with his wife and five children. He recalls how sparks would leap from the outlets of his old mobile unit.
“Today, it’s like Disneyland,” he said.
The challenge of aging parksThe high cost of home upkeep and repair is a challenge bedeviling communities across the country, but mobile home parks in California make for a particularly tough case.
Park residents are much less likely to have the spare money necessary to make home repairs. Nor are they as likely as traditional homeowners to be able to turn to insurance or home loans. Affordable coverage for manufactured housing can be hard to come by and banks don’t typically see them as worthy collateral.
That’s especially true of older units, many of which were never designed to get old in the first place. Those built prior to 1976, when more onerous federal standards went into effect, are particularly vulnerable to moisture, mold and fire damage. They are often poorly insulated, making them uncomfortable — even dangerous — when temperatures fall or spike.
Many of these pre-’76 units are ”probably no longer suitable to be living in,” said Andrew Rumbach, who has studied mobile home parks at the Urban Institute. They’re also disproportionately common in California. According to estimates by Rumbach and his colleagues, nearly 40% of California’s mobile homes were built before federal regulations kicked in, among the largest shares of any state.
Even if a park’s units are in good shape, the parks themselves are often not. Frequently located on the least desirable tracts of land along urban fringes, they are much more likely to be disconnected from public utilities and, increasingly, at risk of wildfire. Sewage, water and electrical infrastructure is frequently owned and operated by the park owners themselves.
“These systems tend to be run by whoever runs the park, which may be an absentee owner or a property manager,” said Gregory Pierce, a UCLA researcher who studies urban planning and water insecurity. “Even if they have the best of intentions, that person may not be well-equipped to run a water system.”
Still waitingEven as the Shady Lane project has been mostly wrapped up for months now, the promised overhaul of Buena Vista Mobile Home Park in Palo Alto has barely begun.
Of the 28 rehabilitation projects awarded funding through the MORE program, Buena Vista, owned and managed by the Santa Clara County Housing Authority, received the most: $24.6 million.
Awarded in the winter of 2023, those funds were initially slated for a full-scale redevelopment project. Decades-old mobile homes would be replaced with new models, as would the community’s leaky gas lines and patchy roads. For the park’s renters, the housing authority proposed a mid-sized apartment complex with a community center.
But in 2024, those ambitions were radically scaled back. Housing authority officials blamed the change of plans on unanticipated cost overruns, a lack of sufficient funding, resident pushback and the fact that the state’s mobile home renovation funding came with a use-it-or-lose-it deadline of mid-2027. In a new plan released late last year, only the park’s common infrastructure — the water, gas, power and sewer lines — will be replaced. Residents from 49 homes have been told that they will be relocated during the eight months of construction and then returned to their existing units.
The Buena Vista Mobile Home Park in Palo Alto on June 16, 2026. Credit: Manuel Orbegozo for CalMatters
An exposed gas pipe at the Buena Vista Mobile Home Park in Palo Alto on June 16, 2026. Credit: Manuel Orbegozo for CalMatters
Sabrina Ramirez at her home at the Buena Vista Mobile Home Park in Palo Alto. Credit: Manuel Orbegozo for CalMatters
The move-out date was originally scheduled for February. It has since been bumped to September.
“It keeps getting pushed back and pushed back,” said Sabrina Ramirez, a childcare worker who has lived at the park since 1999. The uncertainty has been stressful. But the delay through the summer has been good for her dozens and dozens of outdoor plants — a pandemic passion project that now surrounds her 1960s-era home. “My jungle’s loving it. I did not want to move them during the beginning of the year.”
She and Buena Vista’s other plant parents are coordinating with neighbors outside the park to care for the flowers, succulents and fruiting vines once construction begins.
Tapped outThe MORE program ultimately doled out $136 million in repair, replacement and acquisition grants in 2023, but denied applications that added up to another $186 million.
That mismatch between the money requested and the funding available reflects how much need is out there — but it’s also likely an understatement, said Kate Rose, deputy director at the California Coalition for Rural Housing, a Sacramento-based nonprofit. The owners of many parks may simply not have applied because they hadn’t yet heard about the new program. Others — mom and pop owners — might not have had the bandwidth to submit an application on time.
For those projects that lost out or never applied in the first place, additional help is not on the way. The bulk of the program’s prior funding came through one-time budget allocations. The coming year’s strained state budget does not include a top up. The remainder came from a special fund fed with park permit fees. At last count, that fund had $27 million and has grown at less than half of 1% over the last two years. That’s not enough for another statewide funding round, said Rose, who described the total as “peanuts.”
For owners of aging mobile home parks, that doesn’t leave many other options.
When Self-Help Enterprises acquired La Hacienda Mobile Home Park in Fresno, “we really didn’t have a long-term revitalization plan,” said McGovern-Garcia. “We simply knew there had to be an intervention.”
After years of legal turmoil and bad blood between the park’s residents and the prior owner, the site was in rough shape. All of the units except one were built before 1980, she said. Nearly two dozen had been abandoned and left boarded up. Most were beset with water damage and mold.
Self-Help applied for a $3.7 million improvement grant hoping to provide the home owners with low-cost or interest-deferred loans to fund the replacement of the units. They didn’t get it.
“It would have changed the entire trajectory of the community,” said McGovern-Garcia. “It really is like getting Willy Wonka’s golden ticket for the mobile home world.”
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