Under the Ninth Circuit's Miller v. Gammie rule, panels must follow circuit precedent unless it is "clearly irreconcilable" with a later Supreme Court ruling, and Judge VanDyke says that means the Supreme Court's guidance reaches little beyond the cases it actually decides. In a dissent joined by Judges Bumatay and Tung, he urges the justices to overturn the rule so three-judge panels can apply their newer decisions.

— via Volokh Conspiracy (Reason), Eugene Volokh