Obama's most radically leftist nominee to the federal bench has been defeated by GOP filibuster in the Senate. Goodwin embodies the more extremist notions of the living constitution. Powerline discussed Liu's radicalism on several occasions.

The GOP and the Gang of 14 drew a line in the sand on Liu, defining his views as the "extraordinary circumstances" which merit judicial filibusters (see Richard Adams below). Time will tell if this is a singular anomaly or the beginning of a trend of GOP assertiveness on judicial nominations.