When it comes to pushing the Donald J. Trump panic button, hardly anyone has been more industrious than just-retired Sen. Barbara Boxer (D-California).

Last week, with only days remaining before ceding her seat to the newly sworn-in Sen. Kamala Harris (also D-California), Boxer was on the Senate floor orating that the notoriously liberal San Francisco-based Ninth U.S. Circuit Court of Appeals was facing a “judicial emergency.” Translated into standard English, that means that Trump, as president, has the power to fill four vacancies (two current, two looming) out of the 9th Circuit’s 29 active-judge seats during 2017. Those appointments could flip the court conservative—or at least more moderate, which is indeed an emergency if you’re Barbara Boxer.