several legal and political observers began calling immigration enforcement based on racial or ethnic profiling "Kavanaugh stops," and tallying up the growing number of alleged incidents of this type occurring under the Trump administration. All of this may have stung the justice, because he appeared to qualify or walk back this sentiment in his concurrence in the Illinois case. "The basic constitutional rules governing that dispute are longstanding and clear: The Fourth Amendment requires that immigration stops must be based on reasonable suspicion of illegal presence, stops must be brief, arrests must be based on probable cause, and officers must not employ excessive force," wrote Kavanaugh. "Moreover, the officers must not make interior immigration stops or arrests based on race or ethnicity."