Many proponents of reforming the Supreme Court have expressed support for adopting a system of eighteen-year staggered term limits. These proposals, however, are hobbled by constitutional constraints: Amending the Constitution to implement term limits is highly implausible and implementing term limits through statute is likely unconstitutional. These constraints appear to doom the otherwise desirable proposal to limit the Supreme Court Justices' terms of service. Professor Scott Bloomberg of Maine Law has recently published a law review article proposing an alternative path to Supreme Court term limits; one that would avoid those constitutional constraints. In Reform Through Resignation: Why Chief Justice Roberts Should Resign (in 2023), Professor Bloomberg argues that Chief Justice Roberts is uniquely positioned to create a new norm of Justices resigning after serving eighteen years on the Supreme Court. Just as George Washington's decision to not seek a third term as President established a long-lasting presidential term-limit norm, the Chief Justice could establish the same for Supreme Court Justices.