• I ordered an Italian beef sandwich from three Chicago staples: Buona, Portillo's, and Al's Beef.
• Buona's beef was a bit underwhelming, and Al's beef was a bit overpowering.
• Portillo's sandwich took the longest to order, but it was by far the best and worth the wait.

Italian beef is a Chicago staple, and I was excited to try it.

Italian beef is a classic Chicago dish that's increased in popularity after the debut of Hulu's "The Bear," which returned for another season this year. Originally, the show follows a chef returning to Chicago to run his family's sandwich shop that sells — you guessed it — Italian beef.

Originating in Chicago in the 1900s, the iconic sandwiches consist of slow-cooked, thin-cut roast beef and au jus on a French roll. I moved to Chicago from Hawaii, so I was curious to try Italian beef.

I wanted to order it at some of the most popular chains, so I asked a Chicagoan for recommendations and settled on three: Buona, Portillo's, and Al's Beef.

To keep things fair, I ordered the original beef without extra cheese or peppers from each location. I also visited each chain on a Saturday around lunchtime.

First, I stopped at Buona.

Joe and Peggy Buonavolanto opened the first Buona in 1981. The chain's specialty is Italian beef.

Buona has about 30 locations throughout the greater Chicagoland area. 

The chain was spacious and welcoming.

When I walked in, I was surprised by how spacious and open the seating area was — it made for a very welcoming and relaxing environment. There were tons of places to sit, too.

I didn't feel rushed, squished, or like I was in anyone's way. It was a friendly atmosphere, from the reggae music playing over the speakers to the kind employees I interacted with.

The Buona employee who took my order seemed confident I'd love the sandwich.

After I ordered, the cashier told me I'd be seeing her face a lot because everyone always comes back. She seemed very confident, which made me extra excited to try the sandwich.

My Buona sandwich was wrapped in foil and placed in a paper bag.

I could smell the beef and au jus before I even took the sandwich out of the bag. I hadn't tried sandwiches from the other two chains, but I felt like we were off to a promising start.

I was a little disappointed by how skinny the sandwich was.

When I peeled back the paper from the sandwich, I was surprised by how small it appeared. It looked like a skinny log and felt light in my hands.

The sandwich was 6 1/2 inches long, though it was advertised on the menu as being 7. It was also 2 inches wide. Still, not a big deal.

Buona did not respond to Business Insider's request for comment when asked about the sandwich's discrepancy in size.

Before taking the first bite, I reminded myself that size doesn't matter, and I should let the flavors do the talking.

This sandwich didn't quite meet my high expectations for Italian beef.

Upon my first bite, I wasn't sure I'd be back frequently like the cashier said.

Buona's Italian beef was simple. It was flavorful, but the main flavor I tasted was pepper. It wasn't overpowering, but the peppery taste lingered on my tongue long after finishing the sandwich.

The bread was fluffy, and the sandwich wasn't messy to eat.

The roll was light and fluffy and didn't steal the show — there was also a great beef-to-bread ratio.

But the bread was just there and didn't bring much flavor or personality to the sandwich. It felt like just something plain to hold the beef in place. 

The sandwich wasn't messy at all, and I barely needed a napkin since the beef wasn't overly juicy and didn't drip onto my fingers. Still, I wish it had been moister with more of the flavorful au jus.

Overall, Buona had a solid sandwich — but it didn't blow me away.

Measured length: 6 1/2 inches

Measured width: 2 inches

Wait time to order: none

Wait time for beef: two minutes, 54 seconds

The beef on this sandwich kind of reminded me of flavorful, rehydrated beef jerky, which was not disappointing but didn't meet the high expectations set by the cashier. I wasn't sure the beef was enough to make me a Buona regular.

Next, I went to Portillo's.

Portillo's began in 1963 as a small trailer opened by Dick Portillo. Since then, it's become a Chicago staple known for its hot dogs, chocolate cake, cheese fries, and, of course, Italian beef. 

Most of Portillo's 75+ locations are in Illinois, but it's in some other states, including Florida, Michigan, and Arizona.

Portillo's was bustling, but I immediately felt welcome.

As soon as I entered Portillo's, I was greeted by a lively employee who jokingly pulled me in on an invisible rope and guided me to the lines to order in.

The inside of Portillo's felt totally different from the outside. It felt like a funky train station, and there were props and decorations scattered from the floor to the ceiling. The Dean Martin-esque music playing in the background transported me to the 1950s.

There were two lines, each with about 10 people. Customers were constantly coming in and out. Within five seconds of standing in line, two groups had already entered behind me.

It felt like an experience, not just a place to eat.

Based on my phone timer, I waited a little over nine minutes to place my order. But there was so much going on and so much to look at that I didn't even realize I was in line that long. 

While the place was crowded, the ordering system seemed clear and organized.

I even enjoyed the fun way order numbers were called out with phrases like, "number 292, you know what to do" or "number 249, you're next in line."

I couldn't smell my sandwich through the bag, but it looked thick.

There weren't any beefy smells coming from the bag or out of the wrapper.

When I unwrapped my sandwich, I was shocked by its thickness.

It was love at first bite.

Buona set my baseline for Italian beef, so I was immediately surprised when I bit into Portillo's sandwich.

Portillo's Italian beef was super meaty and rich and had layers of flavors, which I felt were somewhat lacking during my Buona experience. The beef here was also generously packed.

The gravy and beef in Portillo's sandwich were very flavorful, and the seasonings were balanced so that one didn't overpower the other. All the seasonings melded very well together.

I didn't see a measurement for the regular sandwich on the menu that I ordered, but this was 6 inches long. It was 2 1/2 inches wide, thicker than the Buona sandwich.

It was clear this sandwich wasn't just thrown together.

The flavors of the beef tasted like they were developed and created over time during a slow process. 

The French bread that kept the beef in place was soft and fluffy but crusty on the outside, which allowed for the tender beef to nicely mingle with the pillowy inside. It smelled and tasted freshly baked. 

I felt like I could taste the time, effort, and care that was put into this sandwich, which was extra surprising considering how busy the chain was.

Overall, Portillo's beef was worth waiting for.

Measured length: 6 inches

Measured width: 2 1/2 inches

Wait time to order: nine minutes, 23 seconds

Wait time for beef: three minutes, 48 seconds

I initially had my doubts about Portillo's because it has "hot dogs" on its signs instead of beef, but after devouring its Italian beef, I was blown away. Each part of the sandwich was incredible.

Lastly, I visited Al's Beef.

In 1938, Al Ferreri and his sister and brother-in-law, Frances and Chris Pacelli Sr., opened the beef stand that would become Al's decades later in a new location.

Al's logo says it has the "#1 Italian beef," a title the chain added after Chicago magazine named it the best Italian beef sandwich in Chicago in 1980.

The award-winning chain has five locations, and four of them are in Chicago.

Al's felt a bit cramped, but it was beautiful inside.

As I opened the doors to Al's, "bold" was the first word that came to mind.

All the chairs and accent colors of the interior were bright yellow. The seating area was clean and pretty, but it did not seem as open as it was at Buona and Portillo's.

Al's felt much smaller and tighter than the other chains since the tables and seating arrangements were very close together. Still, this place looked good. It felt cool.

Al's had a very hip and fast-paced energy.

With the hip decor and Jack Harlow and Harry Styles songs playing in the background, Al's felt like a trendy local spot for 20- to 30-year-olds to grab a quick bite to eat with friends.

There were a handful of people eating their sandwiches at Al's, but no one was in line to order.

I don't know whether it was the eatery's setup or the attentiveness of the workers behind the counter, but Al's felt fast-paced. I almost felt rushed into ordering, even though it wasn't very busy.

Al's sandwich was definitely the messiest.

As soon as I got my sandwich, I could tell it was going to be a doozy.

Unlike at Buona and Portillo's, the paper wrapping of the sandwich was soaked in au jus. I could tell this would be the messiest of the three and that napkins and moist towelettes would be needed. 

Still, I was excited — this meant the sandwich wouldn't be dry.

The sandwich from Al's almost had an autumnal taste.

I ordered the regular sandwich, which clocked in at 5 1/2 inches. With a thickness of 2 3/4 inches, it was probably the most well-stuffed.

As I leaned in for the first bite, I immediately smelled a ton of indistinguishable spices. It was a bit overwhelming — the smell of Buona's sandwich was more appetizing to me.

My first impression was that the sandwich was salty, but that was immediately overpowered by the spice. I get what the chain means by "distinguishable" and "unique" taste.  

It might sound weird, but the taste of the beef and its au jus kind of reminded me of a fall-themed candle.

The beef was flavorful, but I wasn't sure about it.

The beef had incredibly bold flavors, but I wasn't sure I loved how these spices paired with beef. 

I loved how fluffy and thick the French bread was, and it mostly did a good job of soaking up the au jus. If I loved the au jus, this would've been a good thing. Unfortunately, I didn't exactly want to hold on to the flavors. 

Still, this beef is award-winning, so it might just be my personal preference, or I may have just gotten an extra-seasoned batch.

The bread also got pretty soggy while I was eating.

Since the bread soaked up all the meaty juices, it quickly became soggy.

As I picked up the sandwich between bites, I felt like I had to be really gentle. It felt like the bread could fall apart at any moment. 

Still, I have to give the chain kudos for such a moist sandwich — I was glad it wasn't too dry. That said, it was so soggy I don't think it would hold up well enough for me to eat the rest of it later.

Al's Italian beef wasn't No. 1 for me.

Measured length: 5 1/2 inches

Measured width: 2 3/4 inches

Wait time to order: no wait

Wait time for beef: two minutes, 8 seconds

Al's beef had a very bold and distinct flavor, but I found the execution a bit lacking. In Al's case, I think less might be more.

The amount of meat I got on the sandwich was impressive, but I thought there were too many seasonings and spices that took away from the fluffy bread and super tender beef.

Overall, Portillo's is the only chain I'd go back to if I wanted Italian beef.

The sandwiches from Buona, Portillo's, and Al's each had their own distinct appearance and taste. The chain locations also had unique personalities and vibes, which I also loved.

There really is a chain for everyone, whether you prefer your sandwiches simple or loaded to the max or want a chill, cool vibe or vibrant, bustling one.

For me, Portillo's had the perfect balance of everything I wanted.

Buona's sandwich felt a little too skinny and dry to me, and I wished it had more flavor. On the other end of the spectrum, the sandwich from Al's felt a bit too overloaded with flavor and au jus.

Portillo's Italian beef had complex and delicious flavors, and I loved the fresh-tasting bread. The vibes inside the location I visited were also so fun. I get why the line was so long, and I'd easily wait 10 minutes to order this sandwich again. In fact, I'd wait even longer. 

This story was originally published on August 16, 2022, and most recently updated on July 1, 2024.

• Tourists aboard a submersible saw the rare giant phantom jellyfish during a Viking cruise.
• Viking Octantis is a luxury ship that travels to Antarctica and often has researchers aboard.
• Viking published its first scientific paper in 2023 based on the jellyfish encounters.

Not so long ago, giant phantom jellyfish were an extremely rare sight, with fewer than 130 known sightings. Then tourists aboard personal submersibles started spotting them near the Antarctic Peninsula.

The submersible rides were part of a Viking Expedition trip. Viking Octantis, a luxury cruise vessel, takes thousands of passengers each year through the icy waters of the Southern Ocean to glimpse penguins, seals, and other wildlife.

All the majestic scenery and cruise ship amenities come with a healthy dose of science and the opportunity to contribute to cutting-edge Antarctic research. Trips start at $13,000 for a 13-day cruise.

Searching the deep seas for phantom jellyfish

While scientists started using personal submersibles with increasing frequency in the 1990s and 2000s, Antarctic waters are generally still difficult and expensive to get to. Hopping in one right from Viking's cruise ship makes things a little easier.

And it's novel enough that every trip might lead to something unexpected. "The exciting thing is we can go into the water and say there's a very real chance we might find something that is genuinely new," Damon Stanwell-Smith, Viking's head of science and sustainability told Business Insider.

Viking's Octantis has two, six-passenger submersibles, which take guests down to depths of nearly 1,000 feet.

It was during three such trips in early 2022 that Viking tourists snapped pictures and took video of the giant phantom jellyfish. A year later, other guests had spotted a handful more, National Geographic reported.

First described in 1910, the jellyfish has an umbrella-like body with four ribbony arms, which help trap prey and can grow to over 33 feet each.

Finding the jellyfish has proven difficult in the past, and many mysteries remain about its habits. While they're typically observed in deep water, all the Viking sightings were at less than 1,000 feet deep.

Based on the guests' jellyfish encounters, the ship's researchers published a scientific paper in 2023 in the peer-reviewed journal Polar Research discussing how submersibles can help lead to breakthroughs in Antarctica's under-studied waters.

An expedition ship built for luxury and discovery

In addition to hangers built for subs, the Octantis and its sister ship, Polaris, were designed for many other types of science. There are 380-square-foot laboratories with equipment sophisticated enough for environmental DNA testing.

Stanwell-Smit said this capability is cutting-edge for any research vessel, not a cruise ship. "This is incredibly novel," he said. It lets researchers genetically sequence biological samples right away instead of waiting months for another laboratory to do the work.

The cruise line's commitment to science attracts a certain kind of tourist, which Stanwell-Smith refers to as the "retired professor demographic."

The expedition ships cater to these educated, curious guests by letting them participate in research alongside the nine scientists on every voyage, whether to Antarctica or through the US's Great Lakes.

Guests can listen to expert lectures from the ships' resident wildlife naturalists or provide citizen scientist data about the birds they spot. Or they can get involved in what Stanwell-Smith calls "real science" by assisting on-board geochemists or oceanographers with research.

They can take a sample of phytoplankton, watch a weather balloon launch, or prepare a "bait popsicle" to help with a species-monitoring project.

Prepping the smelly bait is one of the expedition ships' most popular activities, Stanwell-Smith said. "There's a subset of our guests who want to roll up their sleeves, put a lab coat on, and just get really messy," he said.

For those who weren't experts before, Stanwell-Smith thinks the cruise will help them embrace the idea of loving what you know and protecting what you love.

"There is something very visceral about feeling you know something better by having actively done it rather than just watch somebody else or seen it on the screen," he said.

Plus, they might witness something completely new that gets written up in a scientific journal.

• "House of the Dragon" introduced Ulf, a common man who claims to be a Targaryen bastard.
• His claim may have merit — in "Fire and Blood," he proves to be a pivotal character.
• Here's who Ulf is in "Fire and Blood," and what happens to him in the book. 

Warning: Spoilers ahead for "House of the Dragon" season two, episode three, and the book "Fire and Blood."

This week's episode of "House of the Dragon" took a brief detour into the seedier parts of King's Landing — and in the process, it introduced us to yet another character who will likely serve a pivotal role later in the series.

Season two, episode three, titled "The Burning Mill," briefly spotlighted a cheery bar patron, Ulf. After working the room a bit, Ulf settles down at a table and almost immediately claims to a stranger he's a Targaryen descendant.

While it'd be easy to dismiss Ulf's claim as drunken hearsay, there's probably some merit to it. We're probably going to be seeing a lot more of Ulf in "House of the Dragon," depending on how closely it follows "Fire and Blood," George R.R. Martin's history of Westeros.

If you're not keen on spoilers for "Fire or Blood," or the potential future of "House of the Dragon," best not to read ahead.

Ulf claims to be the son of Baelon the Brave, and thereby a descendant of King Jaehaerys

At the tavern, Ulf meets a Dornish man and remarks that Dorne was one part of Westeros that his house never conquered. When pressed, he plays coy, and then lets slip that King Jaehaerys was his grandsire. His father, he says, was Baelon the Brave, making Ulf the illegitimate brother of Daemon Targaryen and King Viserys.

Ulf also refers to Rhaenyra — his niece, if his claims are to be believed — as the "one true queen," a dangerous move in the Aegon II-controlled King's Landing.

"The blood of the dragon runs through these veins, and yes, men would take my head for it," Ulf says. "A Dragonseed must watch his own neck when he has no white-cloaked guardsmen to do it for him."

Ulf eventually shuts up after saying that his "nephew," Prince Jacaerys Velaryon, is the rightful heir to the Iron Throne. Coincidentally, that's the moment that Aegon II walks in with his entourage — and Ulf is quick to call out an "All hail the King!"

Ulf becomes a dragon rider in 'Fire and Blood'

In "Fire and Blood," Prince Jacaerys issues a challenge in a bid to make use of the unclaimed dragons during the war: Any man able to successfully mount a dragon without a master would be richly rewarded. Some of those men were "seeds" — bastards who had Targaryen blood in their veins.

Ulf successfully bonded with Silverwing, the former mount of Queen Alysanne, the sister and wife of King Jaehaerys. During that time, he was referred to as "Ulf the White" or "Ulf the Sot," referencing his white hair and drinking habit. Eventually, he came to be known as Ulf White.

Ulf fought alongside other dragon riders like Hugh Hammer in the Battle of the Gullet, a pivotal sea battle during the war. "Fire and Blood," citing the historical record left by the dwarf Mushroom, recounts that both Hugh and Ulf celebrated after the violent battle, with Ulf declaring that they should become lords.

Ulf and Hugh were several times denied entry into nobility. Rhaenyra shut down a potential marriage between Ulf and the daughter of Lord Stokeworth, after killing the lord for betraying her. She also denied Daemon's proposal of granting Storm's End, the seat of House Baratheon, to Ulf, after the Baratheons sided with Aegon II during the war.

In the book, Ulf and Hugh betrayed Rhaenyra

During the war, Ulf, Hugh, and their dragons Silverwing and Vermithor, were sent to the town of Tumbleton to defend it from Lord Ormund Hightower, who was advancing toward King's Landing. During the battle, however, the two defected and attacked the town instead.

According to Mushroom's historical account in "Fire and Blood," Ulf descended into hedonism, raping multiple women in Tumbleton each night and constantly drinking. Though Prince Daeron, Alicent and King Viserys' youngest son, had named him the Lord of Bitterbridge, he coveted Highgarden, the seat of House Tyrell. He and Hugh refused to advance on King's Landing until they were rewarded sufficiently, and the lords under Prince Daeron conspired to kill them.

But the fight came to Tumbleton when Addam Velaryon (previously Addam of Hull), another dragon rider, attacked the city on his dragon Seasmoke. Ulf was drunk and asleep during the battle, during which Hugh, Daeron, and Addam all died. When he awoke, he agreed to march on King's Landing, and said that he should be instilled on the throne after they conquered it.

Shortly after, Hobert Hightower killed Ulf — and in the process, himself — through a poisoned cask of wine.

"House of the Dragon" season two airs Sundays at 9 p.m. ET on HBO and is streaming on Max.

• Russian forces reportedly used a deadly 3.3-ton glide bomb for the first time earlier this month.
• Video footage appeared to show the FAB-3000 M-54 destroying Ukrainian targets in Kharkiv.
• The new massive bomb's destructive capability and range make it a dangerous threat to Ukraine.

The Russian Aerospace Forces are using a new munition in Ukraine that might change the situation on the ground.

In June, Russian aircraft deployed for the first time the FAB-3000 M-54 glide bomb. Weighing thousands of pounds, the munition can prove quite destructive for Ukrainian military and civilian targets. Ukrainian outlets reported the use of the glide bomb against Ukrainian troop concentration points in Kharkiv Oblast in eastern Ukraine.

Although the bombing itself appears to have been inaccurate, the FAB-3000 M-54's destructive capability is such that even munitions that do not hit their specific targets can be deadly because of their greater destruction radius. The fact that this is a glide bomb and it can be released outside the range of Ukrainian air defenses makes the munition even more dangerous.

"Russian forces used the new FAB-3000 M-54 bomb with a unified planning and correction module (UMPC) to strike Ukrainian positions in Kharkiv Oblast for the first time, representing a new Russian capability with a high potential for destruction if Russian forces continue to be able to use such weapons uninhibited," the Institute for the Study of War assessed in a recent operational update on the war.

Ukrainian Air Force officials, however, noted that they couldn't provide a final estimate on the exact type of munition used by the Russian Aerospace Forces.

The FAB-3000 M-54 is a conventional, or "dumb," bomb that can be converted into a glide munition with the addition of the UMPC.

In March, Russian officials first announced the mass production of FAB-3000 M-54 munitions. Previously, the Russian military had trouble attaching the heavy munition, which weighs almost 7,000 lbs, to tactical aircraft. However, Russian technicians seem to have found a solution.

"The fact that Russian forces have figured out how to launch FAB-3000s is a significant development and will increase the destructive potential of Russia's ongoing glide bomb attacks against Ukrainian forces and infrastructure," the Institute for the Study of War added.

As the conflict continues, the Russian Aerospace Forces have increasingly been relying on guided and unguided glide bombs to hit Ukrainian targets. These munitions are released from long distances and travel or glide to their targets while the aircraft launching them is safely away.

"Russian forces have already increased guided and unguided glide bomb use against Ukraine, particularly in Kharkiv Oblast, to devastating effect, and should Russian forces be able to launch massive barrages of FAB-3000s (or even heavier guided glide bombs), they will be able to cause even more widespread damage to Ukrainian frontline positions and critical infrastructure," the Institute for the Study of War stated.

The performance of the Russian Aerospace Forces

The Russian Aerospace Forces have largely failed in the conflict so far. When it comes to air superiority, although more numerous and with better quality, Russian aircraft have not established control over the skies. Ukrainian pilots have been putting out a stalwart resistance, and there are also too many antiaircraft systems of all ranges on the battlefield.

When it comes to strategic strikes, they have faired only slightly better. Relying on a combination of stand-off and glide munitions, Russian aircraft have been targeting Ukrainian critical infrastructure and urban centers.

However, the questionable quality of these munitions, in conjunction with the powerful — but depleting — Ukrainian air defenses, have largely ensured that these strikes haven't been as consequential to the course of the war as the Kremlin would want.

Finally, in terms of close air support, the Russian Aerospace Forces have done better but their performance is still far from altering the battlefield.

Using fixed- and rotaty-winged attack aircraft, the Russian military has been able to gain tactical superiority during some times and in specific areas of the contact line. But beyond causing some additional casualties to the Ukrainian forces, Russian tactical aviation hasn't made a difference.

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• The immunity decision will delay and diminish Jack Smith's two Trump prosecutions, experts predict.
• In the documents case, Trump can claim that "declassifying" them,  back in DC, was an official act.
• In the J6 case, he can seek immunity for allegations involving talking to another federal official.

It's been a pretty bad day for Special Counsel Jack Smith.

Both of his prosecutions of Donald Trump — the Mar-a-Lago documents case in Florida, and the insurrection case out of Washington, DC — will be delayed and diminished by Monday's United States Supreme Court's immunity decision, legal experts predict.

The SCOTUS decision found that former presidents are presumptively immune from prosecution for acts they took while in office. It leaves it to lower courts to decide whether Trump conspired to overturn the 2020 election.

That review of the insurrection case — by the DC Circuit Court of Appeals and, likely, the Supreme Court once again — will take many months.

Meanwhile, Trump can be expected to use his new immunity superpowers to also challenge the documents case, including by reviving his claim that he somehow "declassified" the papers back in DC, in what was an "official" act.

"With the January 6th case, the one that was at issue here, this makes it absolutely clear there's no way this is going to trial before the election," said Cliff Sloan, a Georgetown University law professor and constitutional law expert.

"For the Florida case, the decision has no direct impact," noted Michel Paradis, an attorney who teaches national security and constitutional law at Columbia Law School.

"But it is likely to disrupt and complicate the prosecution, in so far as there will be a new round of arguments on how the Supreme Court decision affects the transportation of documents, etc.," he said.

Sloan said that it's possible that Trump's attorneys make new arguments in the classified documents case based on the SCOTUS ruling, but explained, "It'll be more difficult because the core of that case has to do with actions he took when he was no longer president with regard to classified documents."

Still, Trump can now argue that before he left office, he somehow "declassified" the documents, an official act that now cannot be challenged.

Prosecutors say Trump broke federal law when he took documents with him from the White House to Mar-a-Lago, his Palm Beach, Florida, estate and private club.

The Florida litigation will be all the more complicated, Paradis added, "because the Supreme Court also held that you can't inquire into a president's 'motives' for taking any official act. And so precisely how that will work is up in the air at the moment."

According to Monday's decision, "In dividing official from unofficial conduct, courts may not inquire into the president's motives."

The court continued, "Such a 'highly intrusive inquiry would risk exposing even the most obvious instances of official conduct to judicial examination on the mere allegation of improper purpose."

Circling back to the January 6 case, one of that indictment's allegations is almost certain to now be challenged as an official act for which he is immune from prosecution, said Paradis.

Trump is accused of trying to pressure his acting attorney general and the Justice Department to overturn the 2020 presidential election results. Those discussions "are readily categorized" as official acts, Monday's decision states.

This is true even if Smith's claims are correct, and Trump's efforts were improper, the decision said.

"Because the President cannot be prosecuted for conduct within his exclusive constitutional authority, Trump is absolutely immune from prosecution for the alleged conduct involving his discussions with Justice Department officials, the decision said.

"Other allegations — such as those involving Trump's interactions with the vice president, state officials, and certain private parties, and his comments to the general public — present more difficult questions" that will now be argued over, the decision also states.

"The biggest difficulty will be proving that something is not an official act," noted Paradis.

"The way the Supreme Court set up the new rule is that most everything the president does is 'presumptively immune,'" he said.

"It then falls to the prosecution to show that the 'presumptively' official act was in fact 'unofficial.' However — and this is where Justice Barrett broke with the majority — prosecutors can't inquire into the president's motives and are also largely prohibited from inquiring into the president's communications," he added.

"So you have to show what the president intended while being forbidden from proving what was in his mind," Paradis said.

By that new measure, any communication Trump has with another federal official is, for all practical purposes, immune from prosecution, he said.

In its decision, Sloan said, the Supreme Court was "unwilling to say that even a single allegation in the indictment" against Trump over his over his efforts to overturn the 2020 election "was an example of an unofficial act."

"It was willing to say some things were clearly official acts, but it was unwilling to give a single example of something that was unofficial," said Sloan, adding, "Courts would have to sort out what's official and what's unofficial, and if it's official, what kind of official action is it?"

"In addition to everything else, it's a kind of complicated structure, is very unpredictable, and it just puts it in the hands of courts to make these judgments," Sloan said.