Some legal scholars compared the immunity ruling to Dred Scott v. Sandford, calling it one of the worst Supreme Court decisions in history.

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Yale law professor Bruce Ackerman called it "the worst decision since Dred Scott," arguing both rulings invented constitutional protections to shield power from accountability. Harvard's Laurence Tribe said it "betrays the Constitution's text and structure." The comparison emphasizes how the Court manufactured immunity from whole cloth—the Constitution never mentions presidential criminal immunity, just as it never said Black people "had no rights which the white man was bound to respect."

Some legal scholars compared the immunity ruling to Dred Scott v. Sandford, calling it one of the worst Supreme Court decisions in history.

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