basis in written law. The late Supreme Court Justice Antonin Scalia argued as much in his dissent in Crawford-El v. Britton: "[the Supreme Court] find[s] [itself] engaged...in the essentially legislative activity of crafting a sensible scheme of qualified immunities for the statute we have invented—rather than applying the common law embodied in the statute that Congress wrote". Clarence Thomas has likewise expressed "growing concern with our qualified immunity jurisprudence", stating that there is no apparent basis for it in the original intent of the law; in Ziglar v. Abbasi, Thomas urged the court to reconsider qualified immunity, which he considered a doctrine that "substitute[s] our own policy preferences for the mandates of Congress." Some critics have argued that the Supreme Court's creation of qualified immunity amounts to "gutting" Section 1983 of the United States Code, which allows any citizen to sue a public official who deprives them "of any rights, privileges, or immunities secured by the Constitution and laws". U.S. District Court Judge Lynn Adelman has argued that "qualified immunity is a limitation on Section 1983 that the Court created in 1982 without support in the statute’s text or legislative history". University of Pennsylvania professor of law David Rudovsky similarly argued that "the Court...has engaged in an aggressive reconstruction of the scope of § 1983...This reorientation of civil rights jurisprudence has blunted the impact of § 1983". The Court has stated that it bases qualified immunity on three factors: a "good faith" defense at common law, making up for the supposedly mistaken broadening of § 1983, and serving as a "warning" to government officials. But William Baude, professor of law at the University of Chicago Law School, states that "there is no such defense, there was no such mistake, and lenity [warning] should not apply. And even if these things were otherwise, the doctrine of qualified immunity would not be the best response." Ineffectiveness In a 2017 Yale Law Journal paper titled "How Qualified Immunity Fails", UCLA law professor Joanna C. Schwartz examined 1,183 Section 1983 cases and found that it was being invoked primarily when it should not have been, and therefore was being ignored or dismissed frequently. Her conclusion was that it is ineffective for its stated goals in such a way that it could not be strengthened, and should be replaced by other mechanisms for obtaining those ends. Challenges to qualified immunity Through litigation On March 1,