Article II and the Supremacy Clause do not categorically preclude, or require a heightened standard for, the issuance of a state criminal subpoena to a sitting President.

Rejecting a heightened need standard does not leave Presidents with 'no real protection.' To start, a President may avail himself of the same protections available to every other citizen.

Given these safeguards and the Court's precedents, we cannot conclude that absolute immunity is necessary or appropriate under Article II or the Supremacy Clause. Our dissenting colleagues agree,