2023—In Planned Parenthood of the Heartland v. Reynolds, a 3-to-3 deadlock on the Iowa supreme court leaves in place an injunction that bars Iowa’s 2018 heartbeat law from taking effect. The three justices who decline to vacate the injunction invoke procedural complexities that would be easier to credit as genuine if they were not accompanied by tendentious rhetoric and flimsy arguments. One of those three justices is Edward Mansfield, who was on Donald Trump’s list of Supreme Court candidates in 2016.