Donald Trump's Presidential election led Kansas Secretary of State Kris Kobach to advocate for Trump to implement immigration controls like the National Security Entry-Exit Registration System. One Trump supporter, Carl Higbie, said that Jimmy Carter's 1980 restriction on Iranian immigration, as well as the "Korematsu" decision, gives legal precedent for a registry of immigrants. Critics of Higbie argued that "Korematsu" should not be referenced as precedent. Constitutional lawyer Bruce Fein argued that the Civil Liberties Act of 1988 granting reparations to the Japanese Americans who were interned amounts to "Korematsu" having been overturned by history—outside of a potential formal Supreme Court overrule. Another critic of Higbie described "Korematsu" as a "stain on American jurisprudence".