The ICE agent involved in the fatal shooting could try to invoke immunity under the Constitution's Supremacy Clause to try to end state criminal prosecution.

Professor Michael Mannheimer (Northern Kentucky University) is the author of an important new article on "Unpacking Supremacy Clause Immunity."

Galette and Colt force the Court to confront a basic question about modern federalism: whether constitutional immunity doctrines should evolve alongside the governmental forms they regulate, or whether they should remain tethered to an earlier conception of state action that predates the rise of the public corporation.