Notes
1 Last term, the Court dismissed a case because it presented a political question under the second Baker factor. See Rucho v. Common Cause, 139 S.Ct. 2484, 2494, 2507-08 (2019) TA \l "Rucho v. Common Cause, 139 S.Ct. 2484, 2494, 2507 (2019)" \s "Rucho v. Common Cause, 139 S.Ct. 2484 (2019)" \c 3 . Though the Court indicated that the second Baker factor is just one way that a case could pose a political question, it did not identify the other ways. See id. at 2494. Thus, Zivotofsky remains the last case to illustrate the Court’s complete framework for identifying political questions.