Maybe I'm missing something obvious but I don't understand the idea that the president could order some subordinate to do some unlawful act and the president is immune but the subordinate is not. That's very weird and seems very difficult to defend as a policy matter
Everyone agrees, for example (I think!), that if Trump ordered DOJ to make a perjurious sham case out of election fraud, the specific DOJ employees who commit perjury or other unlawful/sanctionable conduct are not immune from liability for that notwithstanding presidential direction
The DOJ employees don't themselves have Trump's constitutional prerogatives but they are necessary for him to pursue his constitutional prerogatives--if you're worried about the chilling of executive action it applies to subordinates too. But seems totally wild to say DOJ employees are immune
Also weird: the Court doesn't resolve whether Trump's effort to influence states' decisions about electors involved official acts. But his effort to make DOJ validate election fraud charges was itself about influencing states' decisions about electors. He's immune as long as he uses intermediaries?
