 Justice Anthony Kennedy wrote a dissenting opinion in which he argued that the plurality opinion and Justice Thomas's opinion both "[create] perverse incentives and [provide] protection for defendants who spend stolen money rather than their own".Justice Elena Kagan also wrote a dissenting opinion in which she stated that "I am not altogether convinced that ... the Government’s interest in recovering the proceeds of crime ought to trump the defendant’s (often highly consequential) right to retain counsel of choice", but ultimately concluded that "United States v. Monsanto" should control the outcome of the case because Luis never asked the Court to overrule "Monsanto" in her arguments before the Court.In her analysis of the case for SCOTUSblog, Amy Howe wrote that "it’s not clear how significant the effect of this decision will actually be" because the government can still "use tracing rules to distinguish between tainted and untainted assets when the two are intermingled".