Professor Gabriel "Jack" Chin's work was cited in the opinions for the Citizens in Charge, Inc. v. Husted by Judge Jeffrey Sutton of the Sixth Circuit. The issue raised by this case was whether a Secretary of State's enforcement of a constitutional statute expose him to personal liability when the law is held to be unconstitutional. The district court ruled that the Secretary of State was denied his qualified-immunity defense, so the case was brought up to the U.S. Court Appeals for the Sixth Court.
Because Citizens in Charge, Inc. v. Husted dealt with issues of qualified immunity and enforcement in Ohio, Professor's Chin work regarding the ratification of the Fourteenth Amendment in Ohio, proved useful in Judge Sutton's opinions.
Judge Sutton ruled to reverse and remand the case, holding that the Secretary of State indeed holds qualified immunity.