Orders today rejected cert. involving American citizenship in American Samoa and a public unions related case written by Justice Souter that might be a signal about the rehearing of the Friedrichs. As some suspected, Thomas wrote the Puerto Rico bankruptcy opinion (Sotomayor/RGB dissent; Alito didn't take part). Unanimous patent case (three justices concurred). And, RBG (with Thomas concurred, doubtful of Indian law precedents) wrote the opinion allowing a minor crime convicted in a tribal court to count as an aggravating factor even though the person had no counsel. The domestic violence angle is covered.