The Supreme Court issued a per curiam opinion this week in Flores-Villar v. United States, a case that raised the issue once again of distinctions in the citizenship rights of children born abroad to unmarried U.S. citizen-mothers and those born to unmarried U.S.-citizen fathers. Noting that Justice Kagan did not take part in the consideration or decision of the case, presumably because of her recent service as Solicitor General, the opinion reads: “The judgment is affirmed by an equally divided Court.” This leaves standing the Ninth Circuit ruling, which upheld the federal statute. My previous post on the case is here and here.