who committed "constitutionally wrongful acts" before 1872. A similar challenge, which a federal court declined to block, was filed against Marjorie Taylor Greene (R-GA) and heard in April 2022 in Atlanta. Greene sued to strike down the law that allowed contesting her eligibility as unconstitutional. Otero County, New Mexico commissioner Couy Griffin was barred from holding public office for life in September 2022 by District Court Judge Francis Mathew who found his participation as the leader of the Cowboys for Trump group during the attack on the Capitol was an act of insurrection under Section 3. This is the first conviction under Section 3 since 1869 (save the previously mentioned overturned conviction). Section 4: Validity of public debt Section 4 confirmed the legitimacy of all public debt appropriated by the Congress. It also confirmed that neither the United States nor any state would pay for the loss of slaves or debts that had been incurred by the Confederacy. For example, during the Civil War several British and French banks had lent large sums of money to the Confederacy to support its war against the Union. In Perry v. United States (1935), the Supreme Court ruled that under Section4 voiding a United States bond "went beyond the congressional power." The debt-ceiling crises of 2011 and 2013 raised the question of what the President's authority under Section 4 is. During the 2011 crisis, former President Bill Clinton said he would invoke the Fourteenth Amendment to raise the debt ceiling if he were still in office, and force a ruling by the Supreme Court. Some, such as legal scholar Garrett Epps, fiscal expert Bruce Bartlett and Treasury Secretary Timothy Geithner, have argued that a debt ceiling may be unconstitutional and therefore void as long as it interferes with the duty of the government to pay interest on outstanding bonds and to make payments owed to pensioners (that is, Social Security and Railroad Retirement Act recipients). Legal analyst Jeffrey Rosen has argued that Section4 gives the President unilateral authority to raise or ignore the national debt ceiling, and that if challenged the Supreme Court would likely rule in favor of expanded executive power or dismiss the case altogether for lack of standing. Erwin Chemerinsky, professor and dean at University of California, Irvine School of Law, has argued that not even in a "dire financial emergency" could the President raise the debt ceiling as "there