I was in the Court when Trump v. Hawaii was handed down. I remember the scorn with which Justice Sotomayor referred to "President Donald Trump" by name. It was visceral. However, in Cargill v. Garland, Justice Sotomayor name-dropped President Trump in a good way. She wrote:
Shortly after the Las Vegas massacre, the Trump administration, with widespread bipartisan support, banned bump stocks as machineguns under the statute.
Now, there is no reason to mention the President's name when referring to a rulemaking. It was a regulation promulgated by ATF, not signed by the President. But the import here is that even a right-wing fascist like Trump thinks this rule is sensible. Moreover, it is strange to think of a regulation having "bipartisan support." Usually, when people on both sides of the aisle agree on a policy, legislators pass a statute, which the President can sign. But there was no statutory amendment here. Indeed, President Trump was quite clear that he didn't want Congress to pass a statute, and directed ATF to change the rule. Presidential administration in action! (Justice Kagan probably was proud.)
