Supreme Court justices have cited Rob Natelson’s research articles by name 40 times.
On January 20, 2026 Rob Natelson garnered his 40th citation from a Supreme Court justice—one of the highest tallies since 2013 for any legal scholar, and highly unusual for someone unaffiliated with a “top 20 law school.” (Traditionally, professors at schools like Harvard and Yale tend to dominate Supreme Court citations.)
The latest came in Justice Clarence Thomas’s concurring opinion in Ellingburg v. United States, in which the court held unanimously that the Constitution’s Ex Post Facto Clauses covered orders in criminal cases in which a convicted defendant was required to compensate his victim. Justice Thomas relied on Rob’s 2003 article on “statutory retroactivity,” of which ex post facto laws are a part.
The case is here; Rob’s citation appears on the 14th PDF sheet, and is highlighted. The article relied on is here.









