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AllAfrica
10 hours ago
- Business
- AllAfrica
US lands African resources with version of Chinese-Russian scheme
A US-brokered peace deal between the Democratic Republic of Congo (DRC) and Rwanda binds the two African nations to a worrying arrangement: one in which a country signs away its mineral resources to a superpower in return for opaque assurances of security. The peace deal, signed in June 2025, aims to end three decades of conflict between the DRC and Rwanda. A key part of the agreement binds both nations to developing a regional economic integration framework. This arrangement would expand cooperation among the two states, the US government and American investors on 'transparent, formalized end-to-end mineral chains.' Despite its immense mineral wealth, the DRC is among the five poorest countries in the world. It has been seeking US investment in its mineral sector. The US has in turn touted a potential multi-billion-dollar investment program to anchor its mineral supply chains in the traumatized and poor territory. The peace that the June 2025 deal promises, therefore, hinges on chaining mineral supply to the US in exchange for Washington's powerful – but vaguely formulated – military oversight. The peace agreement further establishes a joint oversight committee – with representatives from the African Union, Qatar and the US – to receive complaints and resolve disputes between the DRC and Rwanda. But beyond the joint oversight committee, the peace deal creates no specific security obligations for the US. The relationship between the DRC and Rwanda has been marred by war and tension since the bloody First (1996-1997) and Second (1998-2003) Congo wars. At the heart of much of this conflict is the DRC's mineral wealth. It has fueled competition, exploitation and armed violence. This latest peace deal introduces a resources-for-security arrangement. Such deals aren't new in Africa. They first emerged in the early 2000s as resources-for-infrastructure transactions. Here, a foreign state would agree to build economic and social infrastructure (roads, ports, airports, hospitals) in an African state. In exchange, it would get a major stake in a government-owned mining company. Or gain preferential access to the host country's minerals. We have studied mineral law and governance in Africa for more than 20 years. The question that emerges now is whether a US-brokered resources-for-security agreement will help the DRC benefit from its resources. Based on our research on mining, development and sustainability, we believe this is unlikely. This is because resources-for-security is the latest version of a resource-bartering approach that China and Russia pioneered in countries such as Angola, the Central African Republic and the DRC. Resource bartering in Africa has eroded the sovereignty and bargaining power of mineral-rich nations such as the DRC and Angola. Further, resources-for-security deals are less transparent and more complicated than prior resource bartering agreements. The DRC is endowed with major deposits of critical minerals including cobalt, copper, lithium, manganese and tantalum. These are the building blocks for 21st century technologies: artificial intelligence, electric vehicles, wind energy and military security hardware. Rwanda has less mineral wealth than its neighbour, but is the world's third-largest producer of tantalum, used in electronics, aerospace and medical devices. For almost 30 years, minerals have fueled conflict and severe violence, especially in eastern DRC. Tungsten, tantalum and gold (referred to as 3TG) finance and drive conflict as government forces and an estimated 130 armed groups vie for control over lucrative mining sites. Several reports and studies have implicated the DRC's neighbours – Rwanda and Uganda – in supporting the illegal extraction of 3TG in this region. The DRC government has failed to extend security over its vast (2.3 million square kilometers) and diverse territory (109 million people, representing 250 ethnic groups). Limited resources, logistical challenges and corruption have weakened its armed forces. This context makes the United States' military backing enormously attractive. But our research shows there are traps. Resources-for-infrastructure and resources-for-security deals generally offer African nations short-term stability, financing or global goodwill. However, the costs are often long-term because of an erosion of sovereign control. Here's how this happens: Examples of loss or near-loss of sovereignty from these sorts of deals abound in Africa. For instance, Angola's US$2 billion oil-backed loan from China Eximbank in 2004. This was repayable in monthly deliveries of oil, with revenues directed to Chinese-controlled accounts. The loan's design deprived Angolan authorities of decision-making power over that income stream even before the oil was extracted. These deals also fragment accountability. They often span multiple ministries (such as defense, mining and trade), avoiding robust oversight or accountability. Fragmentation makes resource sectors vulnerable to elite capture. Powerful insiders can manipulate agreements for private gain. In the DRC, this has created a violent kleptocracy, where resource wealth is systematically diverted away from popular benefit. Finally, there is the risk of re-entrenching extractive trauma. Communities displaced for mining and environmental degradation in many countries across Africa illustrate the long-standing harm to livelihoods, health and social cohesion. These are not new problems. But where extraction is tied to security or infrastructure, such damage risks becoming a permanent feature, not a temporary cost. Critical minerals are 'critical' because they're hard to mine or substitute. Additionally, their supply chains are strategically vulnerable and politically exposed. Whoever controls these minerals controls the future. Africa must make sure it doesn't trade that future away. In a world being reshaped by global interests in critical minerals, African states must not underestimate the strategic value of their mineral resources. They hold considerable leverage. But leverage only works if it is wielded strategically. This means: investing in institutional strength and legal capacity to negotiate better deals demanding local value creation and addition; requiring transparency and parliamentary oversight for minerals-related agreements; refusing deals that bypass human rights, environmental or sovereignty standards. Africa has the resources. It must hold on to the power they wield. Hanri Mostertl is the SARChI chair for mineral law in Africa, University of Cape Town; and Tracy-Lynn Field is a professor of environmental and sustainability law, University of the Witwatersrand. This article is republished from The Conversation under a Creative Commons license. Read the original article.
Boston Globe
2 days ago
- Entertainment
- Boston Globe
Roger Norrington, iconoclastic British conductor, dies at 91
He led both period-instrument and modern orchestras, using the same interpretive principles, and though some of his performances drew criticism for their brash iconoclasm, many listeners regarded them as insightful and refreshingly original. Get Starting Point A guide through the most important stories of the morning, delivered Monday through Friday. Enter Email Sign Up 'As ever, with his highly idiosyncratic conducting style, one gets, in addition to a Haydn symphony, the Roger Norrington show,' Boston Globe critic Jeremy Eichler wrote in a review of a Handel and Haydn Society's performance of Haydn's Symphony No. 44 in 2008. 'He seems to delight in exuding his own personality at the orchestra through the medium of the music.' Advertisement Mr. Norrington served as an artistic director of the Handel and Hayden Society from 2006 to 2009. 'The organization feels more interesting when he's around,' Eichler wrote. Lanky, bespectacled, bearded and balding, Mr. Norrington projected both affability and authority, and he loved making the case for his ideas -- not only in interviews but also in seemingly off-the-cuff comments at his concerts. He often cited centuries-old treatises as well as his delight in the 'pure' sound, as he put it, of strings playing without vibrato. He once famously referred to vibrato as 'a modern drug.' Advertisement 'It's not about consecrating a sacred object,' Mr. Norrington said about conducting. 'It's about exploring and being curious and having fun.' Rachel Papo/The New York Times Stu Rosner Stu Rosner Toward the end of his career, he preferred to conduct while seated, usually on a high swivel chair that allowed him to turn to the audience to smile conspiratorially at a light moment within the music, and even to encourage applause. He was known to tell audiences that they could applaud between the movements of a symphony or a concerto, a common practice in the 18th and 19th centuries that is frowned on today. He reveled in being provocative. In a 2021 interview with The Telegraph, he referred to his 2007 recording of Mahler's Second Symphony as his 'last hand grenade.' International fame came late to Mr. Norrington. He had built a solid reputation as a choral conductor in the 1970s, when he made a series of well-received recordings with the Heinrich Schütz Choir, an amateur group he formed in 1962 and named after the German baroque composer. He was also the founding music director of the Kent Opera, England's first regional opera company, established by singer Norman Platt in 1969. Yet he was scarcely known outside Britain until 1987, when he released revelatory recordings of the Beethoven Second and Eighth symphonies. They were the first installments of a complete cycle with the London Classical Players, a period-instrument ensemble that Mr. Norrington founded in 1978 and led until 1997. 'I was happy to take things slowly,' he told The Telegraph in 2021. 'I didn't conduct a Beethoven symphony until I was 50. So when I finally stood up in front of the great orchestras of America and Europe as a guest conductor, I actually knew what I wanted. And this meant I could relax and treat music-making as something that is full of love and laughter. Advertisement 'It's not about consecrating a sacred object,' he continued. 'It's about exploring and being curious and having fun.' Mr. Norrington's first Beethoven recordings were striking in their adherence to the composer's metronome markings, which most conductors have considered impossibly fast or, in a few cases, impractically slow. The recordings immediately found a large audience, and by the time the cycle was complete, in 1989, Mr. Norrington's career was white hot. Roger Arthur Carver Norrington was born in Oxford, England, on March 16, 1934. His father, Arthur Norrington, worked for Oxford University Press and later became president of Trinity College, Oxford, and the vice chancellor of the University of Oxford. Roger's mother, Edith Joyce (Carver) Norrington, was a gifted amateur pianist. Roger studied the violin as a child and sang in choirs as a boy soprano. When he auditioned for a performance of Gilbert and Sullivan's 'Iolanthe,' he won the lead role. 'I realized I had some sort of gift,' he told The Guardian in 2007. But, he added, 'I thought I would be like my parents and spend my life doing music in my spare time.' When he entered Clare College, Cambridge, after completing his national service in the Royal Air Force, it was to study English literature. Nevertheless, he performed with -- and, in his final year, conducted -- student ensembles. Advertisement After graduating, Mr. Norrington became an editor at Oxford University Press. But he continued to sing in choirs and to play violin in orchestras and chamber groups. When a new edition of choral works by Heinrich Schütz was published in 1962, he became so eager to conduct the music that he formed the Heinrich Schütz Choir. Despite the choir's name, its repertoire extended from the Renaissance through the 20th century, and it quickly won enthusiastic reviews and a following. It was not until Oxford sent him on a six-month posting to Nairobi, Kenya, late in 1962 that he resolved to devote himself fully to music. When he returned to Britain, he left his job and enrolled at the Royal College of Music in London, where he studied composition, music history and conducting (with Adrian Boult) and played percussion in the orchestra. Recordings by Austrian period-instrument specialist Nikolaus Harnoncourt led Mr. Norrington to reconsider his ideas about conducting and orchestral sound. They also inspired him to read treatises by 17th- and 18th-century musicians and to seek out musicologists such as Thurston Dart, who shaped his ideas about the performance of early music. Norrington's success with the Schütz Choir led to his appointment as music director of the Kent Opera in 1969. In 1986, he established the Early Opera Group with choreographer Kay Lawrence. He and Lawrence married that year. A previous marriage, to Susan McLean May, ended in divorce in 1982. After his Beethoven recordings won him a large international audience, Mr. Norrington began performing regularly in the United States. He made his New York debut in 1989 at Carnegie Hall, leading the Orchestra of St. Luke's, a modern-instruments orchestra. Writing in The New York Times, Will Crutchfield described his performance of Beethoven's Eighth Symphony as 'exhilarating, witty, precise, full of verve and subtlety, fully convincing as to tempo (using Beethoven's markings with some modification for practicality's sake, rather than throwing them out as most conductors do) and wonderfully played.' Advertisement In addition to novel tempos and the absence of vibrato, Mr. Norrington considered a balance of intuition and scholarship essential to his interpretations. He rebelled against the notion that one could re-create historical performance styles by merely playing what was written on the page. And he inveighed against those who treated performances as museum pieces. 'A performance is for now, and one instinctively tailors it for today,' he said in 1989, adding, 'To say that you don't put your personality into it is rubbish.' In November 2021, after Mr. Norrington conducted his farewell concert -- leading the Royal Northern Sinfonia, in northern England, in an all-Haydn concert -- The Guardian called him 'arguably the most important British conductor of the last half century.' Kay Lawrence died in November. Mr. Norrington leaves his son, Thomas; two children from his marriage to May, Ben and Amy Norrington; three grandchildren; a sister, Pippa Sandford; and a brother, Humphrey. 'My story, from 1962, has been one of knocking down wall after wall and seeing what happened,' Mr. Norrington told The Guardian in 2007. 'So to discover right at the end that these great traditional European and American orchestras can be part of it as well has been wonderful. Now even they are beginning to realize you don't need to put vibrato on everything, like sugar.' He added: 'So if, on the day I die, the world is playing without vibrato, of course I will be delighted. But even if they aren't, I'll still be delighted because at least I did.' Advertisement This article originally appeared in
Arab Times
7 days ago
- Politics
- Arab Times
King Hassan II about his son, ‘Mohammed is an extension of my soul'
BUILDING nations begins with building capable leaders. Rather than delving deep into theory, I want to share a story about the late King Hassan II of Morocco (May God have mercy on him) and his vision for his son, King Mohammed VI. His words offer a valuable lesson on nurturing leaders who will succeed in ruling their countries. King Hassan II spoke about his then Crown Prince, Mohammed VI, using simple yet profound words filled with pride, concern, and love. The late King Hassan II said, 'Mohammed is not only my son but he is the extension of my soul. I watched him grow before my eyes, but I was preparing him to carry the nation on his shoulders. I did not teach him how to be a prince, but rather how to be a servant of his country. I know that the crown is a heavy burden, but I saw in Mohammed the patience, wisdom, and quiet strength to understand more than to speak. He listens carefully for a long time, but when he does speak, I feel that Morocco breathes safely. If I am absent, be assured that I have left you a king who resembles me, not only in blood and features but also in his deep love for this country.' --- This is how a 600-year-old empire was brought down. In 1889, a group of students at the Military Medical College in Turkiye founded the Committee of Union and Progress with the backing of Masonic networks. The group claimed its mission was to reform the Ottoman Empire and improve its conditions. However, its true objectives were to undermine the state, weaken the influence of Islam and the authority of the Sultan, and abolish the Caliphate. Many of the committee's members were Freemason Dönmeh Jews. Their ideas quickly spread among intellectuals, public figures, and military officers. The Committee of Union and Progress gained control over the Second, Third, and Fourth Ottoman Armies. In 1908, the committee staged a coup against Sultan Abdul Hamid II, claiming they sought to implement a European-style constitution and establish a parliamentary system similar to that of England, where the people would rule through elected deputies. They succeeded in their mission and secured a majority in Parliament. However, their racist policies toward non-Turks led to major repercussions. Bulgaria and Hungary declared independence, Crete united with Greece, and the Armenians revolted. The blame for these events was placed on Sultan Abdul Hamid II, and Parliament announced his deposition. A delegation, which included a Jewish member, was sent to deliver the decision to the Sultan. He was then exiled and replaced by Prince Mehmed V, who held the title of Sultan but lacked any real power, as the committee controlled all aspects of governance. Under their rule, a horrific massacre was committed against the Armenians. They also forced the Ottoman Empire into World War I, which led to the empire's defeat and collapse. The Armistice of Mudros and the Treaty of Sèvres were signed, leading to the Ottoman Empire losing all its European territories. The Arab countries fell under French and British control. All that remained of the empire were Istanbul and a few island cities. Shortly afterward, the Sultan passed away. Abdulmejid II was appointed Caliph in a symbolic capacity, while behind the scenes, a general from the Committee of Union and Progress, Mustafa Kemal, began to rise in power. He rejected the Treaty of Sèvres and declared a jihad to expel the occupying Greek, Italian, British, and French forces. In 1923, Mustafa Kemal signed the Treaty of Lausanne, which established the modern borders of Turkey. Three months later, the secular Turkish Republic was officially declared, headed by Mustafa Kemal Atatürk. Atatürk exiled all members of the Ottoman dynasty from the country, banned the hijab, the call to prayer, the Hajj pilgrimage, and the teaching of the Quran. He permanently abolished the position of the Caliphate, ending 600 years of Ottoman rule. The history of the Ottoman Empire was filled with both achievements and failures, as it was ultimately a human endeavor. It had powerful rulers such as Osman I, Mehmed the Conqueror, and Murad I, as well as weak ones like Selim II and Mustafa I (known as 'the Mad'), among others.
Yahoo
15-07-2025
- Politics
- Yahoo
Opinion - ‘Forum shopping' for desired legal results is a bipartisan problem
Last month, the Supreme Court limited the ability of federal courts to issue universal preliminary injunctions, temporary rulings that prevent the government from enforcing a challenged law or policy against anyone until the litigation is fully resolved. The decision should be viewed in the context of a larger problem that the Supreme Court found concerning and was attempting to address: In recent years, litigants have been able to increase their odds of success by handpicking the forums — and sometimes even the judges — for their lawsuits. But the court's ruling is not the way to solve this problem. A newly published analysis from NYU School of Law's Institute for Policy Integrity (we are among the co-authors) examines every legal challenge to a federal 'major rule' since 1996, when the Congressional Review Act established the major rules definition. The study reveals that 'forum shopping' is indeed playing an increasingly large role in the fate of major federal policies. And it is a problem that has vexed presidents of both parties. The trend reached its apex during the Biden administration. The study finds that 40 percent of the challenges to the government's major rules were filed in the conservative-leaning Fifth Circuit, the federal courts in Louisiana, Mississippi and Texas. This circuit had never seen more than 10 percent of such challenges in any prior administration. The Biden administration won only 21 percent of these challenges filed in the Fifth Circuit, while it won 68 percent of such challenges filed elsewhere. Litigants do not always have a choice of forum for their lawsuits. For example, most environmental regulations with nationwide impacts must be challenged in the D.C. Circuit. But many challenges can be brought nearly anywhere in the country. Under former Presidents Bill Clinton and George W. Bush, nearly two-thirds of challenges to major rules were still filed in the D.C Circuit. This fell to half of such cases under former President Barack Obama, and dwindled to just over one-third under President Trump's first administration. The figure continued to decline under President Biden. So where are the cases going instead? As the Fifth Circuit example suggests, litigants are shopping for results. During the first Trump administration, litigants challenging major rules favored the liberal-leaning Second and Ninth Circuits — which are headquartered in New York and California — nearly a third of the time. And the first Trump administration saw imbalanced results in these circuits, too. Its win rate in the Second and Ninth Circuits was 28 percent, compared to 54 percent in all other courts. Excluding these circuits would have increased the Trump administration's 45 percent overall win rate by 8 percentage points. While forum shopping is a game that both sides play, the effects are not symmetrical. For example, the Biden administration's overall win rate in challenges to major rules was 45 percent — effectively the same as the Trump administration's — but it would have risen to 68 percent if the Fifth Circuit had been excluded. This 23 percentage point difference is significantly larger than the 8 percentage point decrease for the first Trump administration if the Second and Ninth Circuits were excluded. There is also an increased trend of 'judge shopping.' There are over 1,000 federal district court judges. But of the 130 major rules challenged under the Biden administration, a whopping 16 percent were challenged before just two jurists: Judge Matthew Kacsmaryk and Judge Reed O'Connor of the District Court for the Northern District of Texas, both appointed by Republican presidents. By filing in a particular subdivision of the Northern District of Texas, litigants could effectively choose these judges. Similar judge-shopping did not occur in challenges against the first Trump administration, largely because such loopholes do not exist in courts perceived as favorable to challenges to Republican administrations. It is rational for litigants to play this game. But a system that encourages this kind of behavior — and especially one that produces asymmetrical effects for one side of the political aisle — undermines faith in the fair and even application of law, and thus faith in the judiciary. There is no perfect answer here. But, as Justice Ketanji Brown Jackson noted in her dissent, changing the rules determining which courts hear disputes may better address some of the policy concerns underlying the Supreme Court's ruling than limiting universal injunctions. One solution would be to channel more cases back to the D.C. Circuit, where nearly two-thirds of challenges to major rules used to be filed. Another would be to reduce litigants' ability to select the forum. For example, some challenges filed in multiple courts are already assigned to one of the courts using a lottery system. Another solution may be to assign challenges to major rules (or some other category of federal actions) randomly to a court across the country, regardless of where they were initially filed. Eliminating universal injunctions may dampen some of the effects of forum shopping. (We say dampen because the ruling does not prevent courts from striking down a federal regulation entirely or providing class-wide relief.) Different courts will continue to decide issues of nationwide import differently, and litigants will continue shopping for results. And the Supreme Court's partial fix comes with enormous downside, as it removes a critical check on unlawful executive actions. Whatever the ultimate solution, the status quo is untenable. Extensive forum shopping undermines faith in the judiciary and the rule of law. Ideally, the trends highlighted in the study will prompt scholars, practitioners and lawmakers to give this question serious thought, and identify bipartisan reforms that still ensure meaningful ways to challenge unlawful executive actions. Don Goodson is the executive director of the Institute for Policy Integrity at NYU School of Law, where Bridget Pals is an attorney. Copyright 2025 Nexstar Media, Inc. All rights reserved. This material may not be published, broadcast, rewritten, or redistributed.
The Hill
15-07-2025
- Politics
- The Hill
‘Forum shopping' for desired legal results is a bipartisan problem
Last month, the Supreme Court limited the ability of federal courts to issue universal preliminary injunctions, temporary rulings that prevent the government from enforcing a challenged law or policy against anyone until the litigation is fully resolved. The decision should be viewed in the context of a larger problem that the Supreme Court found concerning and was attempting to address: In recent years, litigants have been able to increase their odds of success by handpicking the forums — and sometimes even the judges — for their lawsuits. But the court's ruling is not the way to solve this problem. A newly published analysis from NYU School of Law's Institute for Policy Integrity (we are among the co-authors) examines every legal challenge to a federal 'major rule' since 1996, when the Congressional Review Act established the major rules definition. The study reveals that 'forum shopping' is indeed playing an increasingly large role in the fate of major federal policies. And it is a problem that has vexed presidents of both parties. The trend reached its apex during the Biden administration. The study finds that 40 percent of the challenges to the government's major rules were filed in the conservative-leaning Fifth Circuit, the federal courts in Louisiana, Mississippi and Texas. This circuit had never seen more than 10 percent of such challenges in any prior administration. The Biden administration won only 21 percent of these challenges filed in the Fifth Circuit, while it won 68 percent of such challenges filed elsewhere. Litigants do not always have a choice of forum for their lawsuits. For example, most environmental regulations with nationwide impacts must be challenged in the D.C. Circuit. But many challenges can be brought nearly anywhere in the country. Under former Presidents Bill Clinton and George W. Bush, nearly two-thirds of challenges to major rules were still filed in the D.C Circuit. This fell to half of such cases under former President Barack Obama, and dwindled to just over one-third under President Trump's first administration. The figure continued to decline under President Biden. So where are the cases going instead? As the Fifth Circuit example suggests, litigants are shopping for results. During the first Trump administration, litigants challenging major rules favored the liberal-leaning Second and Ninth Circuits — which are headquartered in New York and California — nearly a third of the time. And the first Trump administration saw imbalanced results in these circuits, too. Its win rate in the Second and Ninth Circuits was 28 percent, compared to 54 percent in all other courts. Excluding these circuits would have increased the Trump administration's 45 percent overall win rate by 8 percentage points. While forum shopping is a game that both sides play, the effects are not symmetrical. For example, the Biden administration's overall win rate in challenges to major rules was 45 percent — effectively the same as the Trump administration's — but it would have risen to 68 percent if the Fifth Circuit had been excluded. This 23 percentage point difference is significantly larger than the 8 percentage point decrease for the first Trump administration if the Second and Ninth Circuits were excluded. There is also an increased trend of 'judge shopping.' There are over 1,000 federal district court judges. But of the 130 major rules challenged under the Biden administration, a whopping 16 percent were challenged before just two jurists: Judge Matthew Kacsmaryk and Judge Reed O'Connor of the District Court for the Northern District of Texas, both appointed by Republican presidents. By filing in a particular subdivision of the Northern District of Texas, litigants could effectively choose these judges. Similar judge-shopping did not occur in challenges against the first Trump administration, largely because such loopholes do not exist in courts perceived as favorable to challenges to Republican administrations. It is rational for litigants to play this game. But a system that encourages this kind of behavior — and especially one that produces asymmetrical effects for one side of the political aisle — undermines faith in the fair and even application of law, and thus faith in the judiciary. There is no perfect answer here. But, as Justice Ketanji Brown Jackson noted in her dissent, changing the rules determining which courts hear disputes may better address some of the policy concerns underlying the Supreme Court's ruling than limiting universal injunctions. One solution would be to channel more cases back to the D.C. Circuit, where nearly two-thirds of challenges to major rules used to be filed. Another would be to reduce litigants' ability to select the forum. For example, some challenges filed in multiple courts are already assigned to one of the courts using a lottery system. Another solution may be to assign challenges to major rules (or some other category of federal actions) randomly to a court across the country, regardless of where they were initially filed. Eliminating universal injunctions may dampen some of the effects of forum shopping. (We say dampen because the ruling does not prevent courts from striking down a federal regulation entirely or providing class-wide relief.) Different courts will continue to decide issues of nationwide import differently, and litigants will continue shopping for results. And the Supreme Court's partial fix comes with enormous downside, as it removes a critical check on unlawful executive actions. Whatever the ultimate solution, the status quo is untenable. Extensive forum shopping undermines faith in the judiciary and the rule of law. Ideally, the trends highlighted in the study will prompt scholars, practitioners and lawmakers to give this question serious thought, and identify bipartisan reforms that still ensure meaningful ways to challenge unlawful executive actions.
