For the 250th anniversary of American independence, I’m going to do three things that Americans love to do: give an ode to the common law, speak ill of our political leaders, and express optimism about the future.

The common law. We do a pretty good job of keeping the spirit of the common law alive. In an age of statutes and regulations and historical illiteracy, we also have lawyers and judges who are trained to think in the ways of the common law and who know the basics of our legal history. That is why our courts can decide, as they did last week in Chatrie v. United States, that the government conducts a search when it gets your location data from Google, even though you “volunteered” to share the data with Google. New social realities, new rules, but wearing the same doctrinal clothes. Common law!

At common law, basically everyone born in England was an Englishman. Although the antebellum Supreme Court, in Dred Scott v. Sandford, rejected the common-law rule as it should have applied to black Americans, in the aftermath of the Civil War, we adopted the Fourteenth Amendment, which restated the common law rule: “All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the state wherein they reside.” In recent years, there has been a weird and unsettling effort on the right, catalyzed by Donald Trump and abetted by smart people who should know better, to say that children of people who are in the United States illegally are not citizens by virtue of their birth here. I’m not going to explain their theory or why it is not just implausible but plainly wrong or why it’s shocking that it wasn’t unanimously rejected by the justices of the Supreme Court in Trump v. Barbara, decided just last week. But by the barest of margins, the Court reaffirmed that the Fourteenth Amendment constitutionalizes the rule of jus soli, which applies almost everywhere in the New World. Here is Chief Justice Roberts’s peroration, which is set off from the rest of the opinion by three asterisks, like this, “* * *”, so you know it’s the good part:

Again and again, the dissents cast the common law as “feudal,” “medieval”—a remnant of “the darkness of the middle ages.” Post, at 4–5, 45, 54, 64, 75–78 (opinion of THOMAS, J.); see post, at 1 (opinion of GORSUCH, J.); post, at 2, 4, 27 (opinion of ALITO, J.).

That was not the view of the Reconstruction Congress. Where the dissents see feudalism, the Framers of the Fourteenth Amendment saw emancipation. By the time of the Glorious Revolution in 1688, in fact, the tie created by birth was less a “duty” than a “right”—the foundation of the “ancient liberties” of “free-born subjects.” H. Muller, Subjects and Sovereign 16–18, 57–58 (2017). That is why Blackstone described the “privileges” owed to the “natural-born.” 1 Blackstone 361–362. That is why the colonists demanded the “rights of Englishmen” more than 250 years ago. B. Bailyn, The Ideological Origins of the American Revolution 192 (1967). And that is why abolitionists lauded the “ancient and universal” rule of citizenship by birth alone as “an ordinance of Heaven.” Yates 36–37; see also M. Jones, Birthright Citizens 89–107 (2018).

Citizenship, then and now, was the right to have rights—to freely participate in our political community. The Framers of the Fourteenth Amendment extended that promise to “every free-born person in this land.” Cong. Globe, 39th Cong., 1st Sess., at 600 (Sen. Trumbull). We keep that promise today.

I’m going to combine the second and third items on my agenda for this post, speaking ill of our politicians and expressing optimism. We’re going through a very rough patch now. We’re being led at the national level by the most corrupt, the least attached to our civic norms, and, I’m sorry to say, the dumbest and least effective. I’d hesitate to say that I’d almost rather have effective malignant government that what we have now. Our other political actors have been feckless and cowardly in their refusal to exercise their powers to deal with the problem. And the opposition party seems to be a spent force with little to inspire Americans’ confidence. We have demoralized our people at home and undercut and embarrassed ourselves abroad. So if, at this 250th anniversary of our independence, we have reached the end of America as the leader of the free world and the end of the line for a government that at least nods to civic virtue—an end that our founders would have told us is inevitable in the long run—then I hope at least we can accommodate ourselves to it with more grace than most of the great states that came before us ever managed to do.

However, at least for the last two hundred fifty years, it’s never been a great bet to bet against America. This summer in Boston, the heart of revolutionary America all those years ago, it’s been great to see our own country through the eyes of the thousands, or maybe by the time it’s over, millions of visitors who have traveled here for the soccer, or for the Fourth of July celebrations, or for the tall ships coming to town in the next few days. I’ve heard countless variations on a theme: “I was worried about coming to America, and I was expecting a dystopian hellscape full of malign cops and ICE agents, mean-spirited, gun-toting, sedentary junk food eaters, and a lot of other doom and gloom. But the people were warm and welcoming! The police were there to help us! The trains even worked! This is the America we miss!” That’s the country I know and love, and if we can just get past this rough patch and agree never, ever to do it again, I have hope that we’ll have yet another new birth of freedom as we start our next 250 years.

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At the sole election of [Columbia], any disputes shall be resolved by arbitration in accordance with the Construction Industry Arbitration Rules of the American Arbitration Association.

Cannistraro did work under the subcontract and made monthly requisitions for payment. It also submitted change order requests, which Columbia rejected. Nevertheless, Cannistraro sent invoices for nearly $1 million for payment for the change order work. Columbia rejected the invoices, but it did not include with its rejection a certification under Massachusetts’s “prompt pay” statute, which requires a certification that the rejection was made in good faith. Cannistraro sued for the amount of the invoices, and Columbia moved to compel arbitration. The court granted the motion, and the case was then arbitrated. The arbitrator decided, apparently in an interlocutory order and not in the final award, that under Massachusetts law, the certification of good faith was essential, and that without it, the invoices were deemed to have been approved. He ordered Columbia to pay the invoices. Columbia paid, but it sought and received permission to assert a new counterclaim seeking recoupment. The arbitrator then held an evidentiary hearing, found that the recoupment claim was not barred by the prompt pay statute, that the invoices were not fair and reasonable, and that Columbia was entitled to damages. Cannistraro moved to vacate the award under the Massachusetts Uniform Arbitration Act, arguing that the arbitrator had exceeded his authority. After that, but before the judge acted on the motion to vacate, the Supreme Judicial Court held that a contractor that had not paid an invoice could not invoke a common law defense to a subcontractor’s breach of contract claim if the contractor had not paid the invoice. In light of the new decision, the judge found that the arbitrator had exceeded his authority. The SJC granted an application for direct appellate review (which means the case went directly to the SJC, bypassing the intermediate Appeals Court).

Massachusetts precedent provides that an arbitrator exceeds his authority “by granting relief beyond the scope of the arbitration agreement, by awarding relief beyond that to which the parties bound themselves, or by awarding relief prohibited by law.” But the SJC explained that “relief prohibited by law” is not the same as relief resulting from an “error of law.” And mistake of law is not a basis for vacating an arbitral award. Rather, it is relief that “offends public policy” or “directs or requires a result contrary to express statutory provision.”

The decision was not contrary to an express statutory provision, even though it was contrary to the statute as the SJC later interpreted it. Public policy is a squishier basis for vacating an award, and the court noted the importance of preserving the deference accorded to awards to avoid “judicializing” the arbitration process. It explained that public policy had been almost exclusively a way of reversing arbitral decisions requiring the government to reinstate public employees who had “engaged in malfeasance.” The exception has to be kept narrow, and the court found it hadn’t been met. The court’s explanation is, in my view, not terrific: the discussion focuses on the reasons why the arbitrator’s decision about the law and the facts was reasonable. It’s not really clear what public policy was said to be violated. In any event, the court came to what seems clearly to be the right decision: it reversed and remanded for entry of a judgment confirming the award.

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1. Everyone agrees that the Convention is exclusive, which means that when it applies, you have to use one of the methods of service that it authorizes or at least permits. This is the holding of Volkswagen, and the distinction between authorized and permitted methods is found in Water Splash v. Menon.
2. There is no provision in the Convention that expressly authorizes or permits service by email. If any provision does the trick, it’s Article 10(a), which permits service by postal channels—but only when the state of destination has not objected.
3. Countries like China and India have objected. Since the only possible provision that permits service by email can’t be used, the service is improper under the Convention.
4. A court cannot use FRCP 4(f)(3) to authorize a method of service that is inconsistent with a treaty.

Or more briefly, like this:

Limited methods.
Email is not on the list.
The plaintiff’s sad tears.

The case begins with some questions of waiver and timeliness that are not of much general interest. It considers a couple of ancillary Convention questions that are of some interest. First, the court notes that there was a real issue about whether the Convention applied at all, given that the defendant’s address in China was unknown. It remanded for further proceedings on whether the plaintiff had been sufficiently diligent to make that argument stick. The court also rejected a creative but (in my view) obviously wrong argument that emailing the defendant a link to the documents was not a transmission of the documents themselves. If you haven’t transmitted the documents, then how can you really say you have effected service? After all, the plaintiff did not claim it had served the documents fictitiously or by publication.

But leaving those issues aside, it was gratifying to see a court stick the landing and get the right answer for the right reason. The issue is not free from doubt: the Florida state courts continue to get the issue wrong, and the Florida Supreme Court declined to hear an appeal from a case in which I had indicated the intent to submit an amicus brief for Professor Huo Zhengxin explaining why the Florida rule offends the interests of states that have objected under Article 10. But the trend is very, very good.

1. Leaving aside the academic possibilities of Article 19, etc. ︎

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Marriages fall within the exclusive jurisdiction of each of the various states of the United States, and there is no centralized registry through which our diplomatic offices could ascertain the marital status of a U.S. citizen. Furthermore, the federal government of the United States does not record these administrative acts. Consequently, the federal government of the United States does not possess any information regarding the civil status of U.S. citizens.

The Embassy and Consulates of the United States do not issue civil status certificates, apostilled documents, nor do they record any civil documents. Prior to September 1, 2025, U.S. citizens in Japan could make a sworn declaration regarding their civil status before a consular official with notarial authority. However, the consular official had no means to verify the accuracy of the sworn declaration. The federal government of the United States does not guarantee the veracity of such documentation, does not independently confirm the accuracy of its contents, and does not provide any enforcement mechanism should the statements be inaccurate. Therefore, the U.S. Embassy and its U.S. Consulates General will discontinue offering this service.

I think what the embassy is saying is that because US citizens might make false declarations regarding their capacity to marry in Japan (for example, I suppose, falsely stating that they are unmarried, or that if married, the spouse has died or a divorce has become final), the embassy will no longer provide notarial services for such declarations. This makes no sense to me. A notary, or a consular official acting as a notary, administers an oath and certifies the identity of the person who makes the oath. He or she does not guarantee the accuracy of the statements made under oath. And the State Department has a rule, 22 C.F.R. § 92.10, that seems right on point:

If the notarizing officer has reason to believe that material statements in a document presented for notarization are false, and if no basis exists for refusing the notarial service in accordance with § 92.9, he may consider the advisability of informing the applicant that he will perform the service only with a specific waiver of responsibility included in the notarial certificate. Furthermore, a notarizing officer may, in his discretion, add to the specific waiver in the notarial certificate a statement of verifiable facts known to him, which will reveal the falsity of material in the document. However, normally a notarizing officer shall exercise great caution not to limit the general privilege of a United States citizen while abroad to execute under oath any statement he sees fit to make, including mistaken, unnecessary, and even frivolous statements: Provided, That substantial and compelling reasons do not exist which impel restraining action on the part of the notarizing officer. On the other hand, experience has shown the desirability of including, as standard practice, a specific waiver of responsibility in all authentications (§ 92.38) executed in connection with divorce proceedings.

The note from the embassy is so unusual that I suspect there must be a back story to explain why an ordinary disclaimer of responsibility, as outlined in the rule, is insufficient. Perhaps the Japanese authorities have expressed to the embassy unhappiness about false declarations in particular cases? In any event, I don’t think that the embassy’s explanation—civil status in the US is a matter of state law and the federal government has no information about citizens’ civil status—makes any sense.

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The case of the day is Whoop, Inc. v. Serinity Group (D. Mass. 2026). The case is, in a sense, routine, but I wanted to write about it because it’s a Massachusetts decision, because I like the “Whoop” company name, and because it illustrates a couple of familiar but still useful points about service by email.

Whoop, the Boston-based manufacturer of fitness wristbands, sued Serinity, a French company that did business as Aurora, for trade dress infringement, seeking damages and an injunction under the Lanham Act, common law, and Mass. Gen. Laws c. 93A, our statute on unfair and deceptive acts or practices in trade or commerce.

Whoop first sought to serve process on Serinity via a huissier, who tried to make service at the French company’s registered address, but who reported that the company was no longer at that address. Whoop then sought leave to serve process by email, and the court obliged.

Seeking to serve process by huissier was appropriate and in fact a good way to go. France has not objected to service by alternate means under Article 10 of the Service Convention. Thus the Convention permitted Whoop to attempt service “directly through the judicial officers, officials or other competent persons of the State of destination.” A huissier is undoubtedly the officer the drafters of Article 10 had in mind. And FRCP 4(f)(2)(A) authorizes service by the means prescribed by French law.

Once it became clear that Aurora’s physical address was unknown, the Convention had no further role to play. Under Article 1, the Convention simply doesn’t apply if the address of the person to be served is unknown. Some courts impose a duty of diligence here, but there’s no doubt Whoop satisfied whatever obligation of diligence it may have had by attempting service at the address Aurora had registered with the French authorities.

Thus the only issue was whether, under FRCP 4(f)(3), the court should, in its discretion, allow service by email. The judge said yes, since the email address to be used was published on Aurora’s website and Aurora used the website to take orders. The judge also observed that an earlier email sent to that address had not been returned as undeliverable, though I think that is a weak piece of evidence without more technical detail, as it relies on the assumption that Aurora is using a well-behaved email server.

Because France, unlike, say, China, has not made an Article 10 objection, it is worth pointing out that even if Aurora’s physical address were known, and even if the Convention therefore applied, service by email might nevertheless work. Your view on that question will turn on whether you think that commercial email as we know it in 2026 is within the scope of the “postal channels” referred to in Article 10(a).

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In my post on the beginning of the war with Iran, I wrote: ” I have grave concerns about whether this President has the moral authority to take the country to war.” That concern has grown and grown over the last month. And it’s not just a concern about moral authority. It’s a concern about strategic understanding and the ability to make rational decisions.

Today the American president said: “A whole civilization will die tonight, never to be brought back again.”¹ Maybe this is his way of trying to pressure Iran into reopening the Straits of Hormuz, a closure that the Trump administration was obviously unprepared to meet when the war started. Who knows what he is thinking. No doubt he wasn’t really thinking. The point is, war is a deadly serious business and should be led by serious people. As a country, we have to express revulsion at comments like this from our head of state and the commander-in-chief of our armed forces. We cannot have carnival barkers and charlatans at the helm. “War is a matter of vital importance to the State; the province of life or death; the road to survival or ruin.” It is not a TV show.

1. Compare Pres. Truman’s speech after the bombing of Hiroshima. “We are now prepared to obliterate more rapidly and completely every productive enterprise the Japanese have above ground in any city. We shall destroy their docks, their factories, and their communications. Let there be no mistake; we shall completely destroy Japan’s power to make war. It was to spare the Japanese people from utter destruction that the ultimatum of July 26 was issued at Potsdam. Their leaders promptly rejected that ultimatum. If they do not now accept our terms they may expect a rain of ruin from the air, the like of which has never been seen on this earth. Behind this air attack will follow sea and land forces in such numbers and power as they have not yet seen and with the fighting skill of which they are already well aware.” And recall that that much more rational and measured statement didn’t work: the United States ended up bombing Nagasaki before the Japanese finally surrendered. ︎

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The case of the day is Fox Corp. v. Media Deportes Mexico S. de R.L. de C.V. (S.D.N.Y. 2026). The case raises a perennial Letters Blogatory question: when the Hague Service Convention applies, can you serve a temporary restraining order or a preliminary injunction on a defendant in a way that you couldn’t serve the summons and complaint? For example, in a foreign state that has objected to service under Article 10 of the Convention, can you serve the TRO or the preliminary injunction by email?

In today’s case, Fox had licensed Media Deportes Mexico to broadcast sporting events in Mexico. It claimed that MDM had breached the license agreement by obtaining an injunction, in a Mexican court, barring Fox from using the Fox Sports trademarks in Mexico. Fox sued in New York, seeking a TRO to restrain MDM from using the Fox Sports trademarks in Mexico or in the US, and from prosecuting its injunction case in the Mexican courts. The court issued the TRO and authorized Fox to serve the TRO electronically, which Fox did. Fox then asked the court to find MDM and related entities, including MSD, in contempt of court for violating the TRO. Eventually, MSD appeared in the New York case and argued that the service of the TRO by electronic means was impermissible under the Convention. In the meanwhile, the Second Circuit decided the Smart Study case, which held that when the Convention applies and when the state of destination has objected to service by alternate means, service by email is impermissible.

The court rejected MSD’s argument. The judge grounded his analysis in part on the last sentence of Article 15 of the Convention. Here is Article 15 (I’ve omitted the second paragraph and bolded the key language):

Where a writ of summons or an equivalent document had to be transmitted abroad for the purpose of service, under the provisions of the present Convention, and the defendant has not appeared, judgment shall not be given until it is established that—

the document was served by a method prescribed by the internal law of the State addressed for the service of documents in domestic actions upon persons who are within its territory, or

the document was actually delivered to the defendant or to his residence by another method provided for by this Convention,

and that in either of these cases the service or the delivery was effected in sufficient time to enable the defendant to defend.

* * *

Notwithstanding the provisions of the preceding paragraphs the judge may order, in case of urgency, any provisional or protective measures.

That last sentence is obviously key. But I am not certain that it means what the judge thought. I do not think the sentence means, “In case of urgency, the judge can authorize methods of service that the Convention otherwise would not permit.” Instead, I think it means, “The judge can, consistent with the Convention, order provisional or protective measures, even if there is no evidence that the service on the defendant has been accomplished.” The Convention, in other words, is no bar to issuance of a TRO directed to a defendant where there is no proof of service, even though it may, under Article 15, be a bar to issuance of a default judgment against a defendant in such circumstances.

Still, US law of course requires notice to a defendant subject to a TRO before the defendant can be found in contempt for violating the TRO. The trouble is that a TRO implies that there is a need for emergency relief and thus a need to get notice to the defendant very quickly. How to square that need with the Convention?

It seems to me that the key is in Article 1, which provides that the Convention applies “where there is occasion to transmit a judicial or extrajudicial document for service abroad.” If I want to serve a defendant with a summons and complaint, I can’t just send a letter giving the defendant notice that he had been served, even if I include the summons and complaint with my letter.¹ It’s not enough for the defendant to read about the lawsuit in a newspaper. But if I want to make sure a defendant subject to a TRO has notice of the TRO, I think I could simply write him a letter. Or, I suppose, I could put an ad in his local newspaper. What matters, for satisfying due process, is that the defendant has actual notice. So even if I send the TRO, which is undoubtedly a judicial document, by mail, I am not sending it abroad for service. I am just providing notice. That’s the reason why “serving” it (that is, sending it) by email is permissible.

The judge also suggested a reason to distinguish this case from Smart Study. Smart Study, he wrote, involved entry of a default judgment, and this case didn’t. Perhaps the point is that a violation of the Convention really only matters to the defendant when a judgment enters that rests on the violation. But when the Convention applies, it applies, and I think a defendant threatened with contempt of court would disagree with the thrust of the judge’s point. It seems to me that my reading of Article 15 avoids the need to make a point like this.

In short, I think the judge got to the right result, but I think there is a much better and clearer way to get there.

1. Sometimes service by mail is permissible, of course! ︎

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The case of the day is Petersen Energía Inversora v. Argentine Republic (2d Cir. 2026). This was the appeal from the $16 billion dollar judgment in favor of minority shareholders of YPF, who sought damages after Argentina nationalized the company in 2012. Although there were two consolidated cases, I’m going to focus just on one, brought by Petersen.¹ Petersen sued in New York, bringing claims for breach of contract under Argentine law. Their claim was that Argentina was liable because it had failed to make a tender offer before expropriating the shares of the majority owner, Respol, as YPF’s bylaws required. Petersen had pledged its shares to secure loans it had taken to buy them, and it planned to use YPF dividends to pay the lender. But when Argentina expropriated Repsol’s shares, the company stopped paying dividends, so Petersen could not pay its debts. It sought bankruptcy protection in Spain, and in the bankruptcy, it sold a majority interest in its claim against YPF to a subsidiary of Burford Capital, a publicly traded litigation finance firm. In 2018, the Second Circuit denied Argentina’s motion to dismiss on foreign sovereign immunity grounds. Petersen Energía v. Argentine Republic, 895 F.3d 194 (2d Cir. 2018). Usually at Letters Blogatory the FSIA decision is the main event. But this case went the distance and ended with a summary judgment in favor of Petersen on the breach of contract claim, and then a trial on damages. Petersen’s judgment was for $7.5 billion, plus $6.9 billion in prejudgment interest. Burford stood to recover 70% of that, or about $10 billion.

Everyone agreed that the merits were governed by Argentine law, and I don’t have a lot to say about the substance of the Second Circuit’s discussion of the merits, except to say that to this American lawyer, it seems odd to claim that when one shareholder causes a corporation to violate its bylaws, it is therefore liable for breach of contract to another shareholder for damages flowing from the violation. As the court’s opinion observes, the obvious remedy in a case like that is a corporate law remedy. That would mean suing in the courts of Argentina, which for obvious reasons Petersen was not keen on doing.² But isn’t the answer to that just to shrug your shoulders and say that if investing in Argentina is just too risky, perhaps you should do something else with your money?³

A lot of the coverage has been about the implications for Burford in losing its risky bet, and about the implications for big-time litigation finance generally. Given the Second Circuit’s en banc practice and the unlikelihoods that the Supreme Court would grant cert. in a case that turns on Argentine contract law, the panel decision is almost certainly the end of the road, which doesn’t mean that we won’t see an petition for rehearing en banc and a cert. petition, given the amount at stake. Burford has said as much in its press release. I’m sure there will also be coverage about increased borrowing costs for countries like Argentina. But there is one point about how to frame the decision that I’d like to note. Burford characterized the decision as “a remarkable abdication of the Second Circuit’s role as a guardian of the rights of NYSE investors.” I really don’t understand that at all. There can be no question that the forum provided a fair hearing to both sides. But everyone agreed that Argentine domestic law governed the outcome, and while it’s possible that the Second Circuit got the law of Argentina wrong, I don’t see why it makes sense for a US court to interpret the law of Argentina with the goal of protecting US investors. The US does a good job of protecting investors by providing fair tribunals and by having stable and investor-friendly corporate and securities laws that the courts interpret in a consistent way. Burford didn’t purchase its stake in Petersen’s claim against Argentina under any naive illusion that it wasn’t taking a very large legal risk (including a collection risk that I don’t discuss here), and I assume that Petersen didn’t invest in the company under the illusion that it was investing in a Delaware corporation.

1. And I’m going to ignore some of the technical stuff about ADRs and the like. ︎
2. I don’t know if it would have been possible to include an agreement to arbitrate in an Argentine corporation’s bylaws. ︎
3. That problem is the reason why we have investment treaties, but this is not a treaty case. Burford’s press release suggests that an investment treaty arbitration is coming. ︎

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Gavin Newsom, governor of California and potential Democratic presidential candidate, was asked the other day if he is a Zionist. He was like a deer in the headlights. He had just walked back his remarks on Israel and apartheid. Then came the question. He paused, repeated the question, and said something deeply weird and creepy: “I revere the state of Israel.” I can just imagine the political calculations whirling through his head as he struggled to come up with an answer to a simple question that wouldn’t offend anyone. He ended up saying something that I have never heard an American or Israeli Jew say, or for that matter, that I have ever heard anyone say about any state.

Why is this hard? Because on the left, where Gov. Newsom will be seeking votes, “Zionism” has become an all-purpose boogeyman. There is no good reason for this. Zionism is simply the belief that the Jewish people have a right to political self-determination in their land. That’s it! It’s just the belief that the very first sentence of Article 1 of the International Covenant on Civil and Political Rights, “All peoples have the right of self-determination,” applies to the Jews just as much as it applies to all other peoples.

You can be a Zionist and favor the two-state solution to the conflict between Israel and the Palestinians. In fact, that’s the position of the AJC and other leading Jewish advocacy groups, and it’s my position.

You can be a Zionist and oppose actions and policies of the Israeli government. (AJC and me).

You can be a Zionist and oppose actions by Jewish extremists in the West Bank. (AJC, and me).

You don’t have to “revere” the state of Israel to be a Zionist, and frankly, I think most Jews would rather you didn’t. We don’t want to be symbols of all that is good any more than we want to be symbols of all that is bad. And the idea of revering any state is, I think, deeply un-Jewish.

You might be someone who doesn’t believe that any people has a right to a state, someone who thinks that peoplehood just isn’t a basis for collective rights. “I reject nationalism,” or whatever. If that’s you, then I respect your views. You want every state to be more like the “settler-colonial states” (the US, Canada, Australia, etc.), and less like, say, France, or Japan, or any of the many Arab states, or the nascent Palestinian state. Just be sure that you apply your principles in an evenhanded way.

In short, if you think the Jewish people is a people just like any other people, with the same fundamental political rights, congratulations, you’re a Zionist! I wish that instead of cowering in fear in the face of activists who have distorted what Zionism means beyond all recognition for their own malign political goals, smart people like Gavin Newsom, who want to be leaders, should have the courage just to tell it like it is.

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