“He was out there articulating a set of legal principles that were moving the law in a conservative direction,” said Noel Francisco, who clerked for Luttig and would later serve as solicitor general in the Trump administration. “A sharp focus on rules when it comes to separation of powers, a healthy skepticism of the administrative state, upholding laws that reflect more culturally conservative viewpoints. It was very much of a pro-law-and-order approach to the law, very much in favor of holding criminals accountable for their conduct.”