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https://twitter.com/jedshug/status/1591552806296883200There is no knockdown argument that would convince all judges current law authorizes broad debt cancelation. Both HEROES and HEA args rely on contested readings of facially broad discretionary authorities. Each arg has strengths and weaknesses.
https://twitter.com/jedshug/status/1566420680446562304First, contra the title, it's not actually an objection to Biden's plan. It's an objection to the legal reasoning in a memo that may or may not represent the Admin's full legal reasoning and does not limit the Admin's ability to defend its action on appeal.