Notably, President Obama issued his Deferred Action for Childhood Arrivals (DACA) order permitting many young undocumented immigrants to remain in the country on June 15, 2012. Arizona was decided on June 25, 2012. So the idea that the president might use his power to grant a broad class of undocumented immigrants new rights via an executive order would have been very much on the justices’ minds at the time that Justice Kennedy wrote language into the Arizona decision laying out the breadth of the executive branch’s discretion.