O'Connor, Sandra Day
1930–2023

Sandra Day O'Connor — Reagan's first SCOTUS appointment, the swing vote of the Rehnquist Court, and the author of the Casey plurality that preserved Roe under stare decisis — built her post-retirement work around defending judicial independence and civic education: she founded iCivics in 2009 specifically to address what she called the erosion of constitutional literacy, and spent the last decade of her professional life giving speeches warning that judicial independence was under threat from political pressure. Paxton's record represents exactly the institutional pressure on judicial independence that O'Connor warned about: the Texas v. Pennsylvania election lawsuit asked the Court to overturn democratic results, the forum-shopping documented by Tribune/ProPublica is the kind of practice O'Connor's institutional-restraint framework opposed, and the State Bar professional misconduct case is the embodiment of the legal-ethics framework O'Connor championed. Talarico's anti-corruption package — SCOTUS ethics code with recusal rules, financial disclosure, gift limits, judicial independence — is functionally an O'Connor framework implementation. O'Connor would push back on Talarico's more expansive economic policies as the kind of legislative reach that creates federalism problems she spent her career navigating. She'd recognize Talarico's temperament as the closer match to her own institutionalist-Republican framework, even across party lines.