Jodi Kantor and Adam Liptak have a story [gift link] based on the internal memos that circulated before the Court issued the order that marked the beginning of the contemporary shadow docket. As you would expect, it is dominated by John Roberts’s arrogance and impatience about imposing his pro-business policy views on the responsible branches:

Just after 6 p.m. on a February evening in 2016, the Supreme Court issued a cryptic, one paragraph ruling that sent both climate policy and the court itself spinning in new directions.

For two centuries, the court had generally handled major cases at a stately pace that encouraged care and deliberation, relying on written briefs, oral arguments and in-person discussions. The justices composed detailed opinions that explained their thinking to the public and rendered judgment only after other courts had weighed in.

But this time, the justices were sprinting to block a major presidential initiative. By a 5-to-4 vote along partisan lines, the order halted President Barack Obama’s Clean Power Plan, his signature environmental policy. They acted before any other court had addressed the plan’s lawfulness. The decision consisted of only legal boilerplate, without a word of reasoning.

At the time, the ruling seemed like a curious one-off. But that single paragraph turned out to be a sharp and lasting break. That night marks the birth, many legal experts believe, of the court’s modern “shadow docket,” the secretive track that the Supreme Court has since used to make many major decisions, including granting President Trump more than 20 key victories on issues from immigration to agency power.

Since that night a decade ago, the logic behind the Supreme Court’s pivotal 2016 order has remained a mystery. Why did a majority of the justices bypass time-tested procedures and opt for a new way of doing business?

The answer would remain secret for generations, legal experts predicted. “We’ll never know (at least, until our grandkids can read the justices’ internal papers from that time period),” Stephen Vladeck, a law professor at Georgetown, wrote in a newsletter in February marking the anniversary of the order.

The New York Times has obtained those papers and is now publishing them, bringing the origins of the Supreme Court’s shadow docket into the light.

The 16 pages of memos, exchanged in a five-day dash, provide an extraordinarily rare window into the court, showing how the justices talk to one another outside of public view.

You can read the memos at the link in the second-to-last graf above.

When colleagues warned the chief justice that he was proposing an unprecedented move, he was dismissive. “I recognize that the posture of this stay request is not typical,” he wrote. But he argued that the Obama plan, which aimed to regulate coal-fired plants, was “the most expensive regulation ever imposed on the power sector,” and too big, costly and consequential for the court not to act immediately.

In the Trump era, he and the other conservative justices have repeatedly empowered the president through their shadow docket rulings. By contrast, the papers reveal a court wielding those same powers to block Mr. Obama. Justice Samuel A. Alito Jr. warned that if the court failed to stop the president, its own “institutional legitimacy” would be threatened.

The court’s liberals pushed back, but compared with their recent slashing dissents, they were not especially forceful, mostly confining their arguments to procedures and timing.

The papers expose what critics have called the weakness at the heart of the shadow docket: an absence of the kind of rigorous debate that the justices devote to their normal cases.

[…]

On Feb. 5, the internal correspondence obtained by The Times shows, the chief justice circulated a blast of a memo, insisting that the court halt the president’s plan.

His arguments were forceful, quick, and filled with confident predictions. The court was going to give the case a full hearing eventually, he forecast. At that point, the justices would vote to overturn the Obama plan, he said, because it went beyond the boundaries of the Clean Air Act.

For now, the chief justice contended that the court had to act immediately because the energy industry “must make changes to business plans today.”

“Absent a stay, the Clean Power Plan will cause (and is causing) substantial and irreversible reordering of the domestic power sector before this court has an opportunity to review its legality,” he wrote.

In his final paragraph, the chief justice again told colleagues that the E.P.A. had done an end run around the court with the mercury regulation just months before and said the agency had signaled that it was planning to do the same thing again.

The chief justice cited an unusual source for that last point, one that would not ordinarily figure in a Supreme Court opinion: an interview with the BBC in which the E.P.A. administrator at the time, Gina McCarthy, had said “we are baking” the Clean Power Plan “into the system.”

In the memo, he weighed no potential downsides of his proposal and considered no alternatives.

Justice Breyer responded later that day to the chief’s memo but did not address all its points. Such stays were unusual, he wrote, stating his objections mildly.

He skipped over the question of whether the plan was lawful, asking only: Why the rush? The circuit court had already set a date to hear the case in June. The first deadline for power plants to reduce their emissions was six years away; full compliance was not required until 2030. That was plenty of time for the case to play out through the legal system.

The chief wrote right back the next day sounding irritated and blunt.

Speed was vital, he said, because environmental regulation was going to be very expensive for states and the power industry. The sums involved could approach $480 billion, he asserted, and industry groups would have to start preparations immediately.

“Without a stay of the E.P.A.’s rule, both the states and private industry will suffer irreparable harm from a rule that is — in my view — highly unlikely to survive,” he wrote. He was predicting the ultimate outcome of a case that had barely begun to be litigated.

Seeing how little headway Justice Breyer had made, Justice Elena Kagan sounded an alarm. In a memo on Feb. 7, she warned the chief justice that he was departing from the court’s long-established way of doing business.

Court action at this point in the process would be “unprecedented,” she added. She mentioned that she was inclined to find that the Obama plan was lawful, but she said the thin briefing made it difficult for her “to determine with any confidence which side is ultimately likely to prevail.”

Justice Alito issued a salvo on the same day as Justice Kagan, with neither of them addressing the other. Echoing the chief justice’s sense of insult and suspicion about the Obama administration, he wrote that the E.P.A. appeared to be trying to render the court irrelevant.

[…]

As usual, the decision would come down to Justice Kennedy.

On Feb. 9, he dashed off a quick, three-sentence note. He believed that the Supreme Court would ultimately stay the Clean Power Plan soon anyway, and that there was no reason to put off the inevitable. He was voting with the chief justice.

Over just five days, the justices had decided the issue. Even as they debated the Obama plan’s possible burden on the power industry, in the entire chain of correspondence obtained by The Times, not a single justice, conservative or liberal, mentioned the dangers of a warming planet as one of the possible harms the court should consider.

The most striking thing about the memos is indeed nobody citing the dangers of climate change as a factor to even consider. Admittedly, since the Court’s liberals didn’t want to intervene they had less reason to, but it’s striking that none of Roberts, Alito, or Kennedy suggested that the impact of the order on the environment should be given any weight at all, despite the purpose of the legislation being to mitigate the environmental effects of air pollution. The executive action would impose costs on business, and that’s all we need to know. And the beauty of the shadow docket is that nobody needs to even pretend to think rigorously before casually dismissing a major executive order.

And this is the new normal:

Since then, even as the court’s approval ratings dropped, applications like the one it confronted a decade ago have proliferated, swamping the court’s ordinary work.

This is partly a consequence of a gridlocked Congress and presidents willing to push the boundaries of executive power, particularly Mr. Trump.

But it is also the result of the justices’ decision to entertain emergency requests like the one in 2016, warping procedures that had developed over centuries.

In an appearance this month at the University of Alabama, Justice Sonia Sotomayor reflected on the unceasing flood of emergency applications.

“We’ve done it to ourselves,” she said.

Reading the article is also melancholy inducing because of how conigent the future of the Court was at that moment, how evitable this all was:

In the moment, the case looked like an outlier, not a turn toward a new way of operating, according to people involved. Nor did it look like a final decision on climate policy. Hillary Clinton was the strong favorite to win the presidency later that year. With her election, the court would be poised to take a step to the left.

[…]

It was initially hard to tell how the vote would fall, people familiar with the discussions said. The Supreme Court felt less predictable back then, more alive with debate. The court was technically divided 5 to 4 between justices appointed by Republicans and Democrats, but Justice Kennedy, appointed by President Ronald Reagan, was a true swing vote, “a persuadable person,” as one of those people put it. The term before, he had written the majority opinion to establish a constitutional right to same-sex marriage.

The possibility of a liberal median vote on the Supreme Court for the first time since 1970 was sitting there. Coverage of the 2016 election was dominated by a trivial story about Hillary Clinton’s compliance with email server management best practices. And no, I will never get over that.

The post John Roberts out of the shadows appeared first on Lawyers, Guns & Money.

Hi everyone. If you’re free on May 7th at 11am Pacific, please join me in this webinar where I’ll be discussing board governance with Dimple Abichandani, author of A New Era of Philanthropy, and Monika Kalra Varma, President and CEO of BoardSource. As our world faces increasing challenges, many of the board philosophies and practices we’ve been used to need to change. Drastically. The webinar is free; register here. Attending will net you one hour of credit for your certification of being a badass nonprofit platypus.

Last week, I wrote about the importance of liberal funders investing in progressive leaders the way the right wing invests in conservative ones. A colleague wrote in the comment section on social media, “I don’t think the left is going to win by copying the Right. The Right appeals to the interests of the wealthy. The truly radical Left does not. In fact, the radical Left poses a direct threat. Master’s house, Master’s tools…”

Several colleagues agreed. I think the comment is thought-provoking. The right appeals to the wealthy, whereas true leftists are a threat to those who hoard wealth and power; I can’t agree more.  

However, I do think Audre Lorde’s quote has been frequently used out of context. People bring it up every time I mention learning from the right. Like when I talked about how we need to be politically engaged. Or how we need to use money the way the right does. Whenever anyone suggests learning anything from the conservative movement, someone will mention the quote.

Here is Audre Lorde's full essay where the quote is mentioned. She had been invited to speak at a conference on feminism. From my reading of the essay, she was frustrated being tokenized as one of the few Black women invited to speak. She called out the exclusion by the conference of other women, including those who were poor, lesbian, or from other countries. She called out white women using the same oppressive tactics on other women that men often use against women to maintain the patriarchy. Here’s the extended quote:

“Those of us who stand outside the circle of this society's definition of acceptable women; those of us who have been forged in the crucibles of difference—those of us who are poor, who are lesbians, who are Black, who are older—know that survival is not an academic skill. It is learning how to stand alone, unpopular and sometimes reviled, and how to make common cause with those others identified as outside the structures in order to define and seek a world in which we can all flourish. It is learning how to take our differences and make them strengths. For the master's tools will never dismantle the master's house. They may allow us temporarily to beat him at his own game, but they will never enable us to bring about genuine change. And this fact is only threatening to those women who still define the master's house as their only source of support.”

I’m no Audre Lorde scholar, so please correct me if I misinterpret, but in the context of her essay, it seems the “Master’s tools” she was talking about are things like exclusion, tokenization, and appealing to men for power and legitimacy, tools that white women specifically were using against Black women (and other women of marginalized identities) even as they worked toward advancing feminism. She claims what’s really needed for true liberation is honoring differences and diversity and building community and solidarity.

I'm not sure Audre Lorde would agree that any tool that’s used by “the master” is a “master’s tool.” But it seems many colleagues have that interpretation. This can seriously hamper us in our work by cutting us off from many powerful strategies and resources. If the right-wing uses community organizing effectively (and it has), does that mean progressives shouldn’t do organizing, because that’s now a “master’s tool?”

Maybe it's not a tool itself, but how it's used by "the master," that makes it a "master's tool." Power, for example, is something a lot of people are afraid of and often associate with something used to oppress. But it can be used to liberate. As MLK said, "[A]ll of us have our moral convictions and concerns, and so often have problems with power. There is nothing wrong with power if power is used correctly."

Also, as another colleague said months ago, “What if the master stole some of these tools?” It would certainly be right up the master’s alley to steal stuff the communities they oppress have been using for years. Art, music, community, anything can be corrupted and used by those of privilege to further inequity and injustice. To then call these things “Master’s tools” gives the oppressors way more credit than they deserve while potentially depriving marginalized communities of tools they themselves created.

Imagine there’s a beautiful community garden. Neighbors use it to grow food, medicinal plants, and flowers, all of it benefiting everyone. Over time, a group of neighbors are angry that some people they hate get to benefit from the garden. So they persuade enough other neighbors to plant poison hemlock, which destroys the garden and harms lots of people.

Eventually someone says, “We need to convince everyone to help remove the poison hemlock and plant helpful plants to restore the garden.” But someone else says, “What? Planting?! Planting and gardening are why we have this poison hemlock problem! And ‘convincing’ people? Didn’t those people who wanted to destroy the garden also used “convincing” as a tactic to get us to plant poison hemlock? We can’t use the same strategies as the people who got us into this mess!”

In the above example, gardening itself is not a harmful strategy. Convincing people to do something is not a harmful strategy. Sure, the people who wanted to destroy the garden used these strategies, and they used them effectively to advance their horrible goals, but the activities themselves are neutral.

Which brings us to a lot of the strategies the right wing uses so effectively. Most of them are values neutral, and labeling them as evil or “tools of the master’s” prevents their usage to advance equity and justice.

The right-wing works to elect politicians who are xenophobic, transphobic, misogynistic. Progressives working to elect politicians who are inclusive, supportive of trans people, believe in reproductive rights, and so on, that’s not using the Master’s Tools.

The right-wing invests in their young people to turn them conservative. Progressive organizations and movements investing in our young, teaching them the values of equity, inclusion, and justice using similar means, that’s not using the Master’s Tools.

The right-wing invests in narrative change by creating media channels such as online publications, podcasts, YouTube channels, social media networks, etc. A foundation funding narrative work by supporting local newspapers, creating grants for progressive content creators, and buying up conservative platforms and converting them into progressive ones, that’s not using the Master’s Tools.

The right-wing builds strong and powerful conservative institutions by giving 20-year general operating grants. Liberal funders doing the same thing, providing 20-year grants to left-leaning organizations and movements so that they can be effective in advancing progressive values, that’s not using the Master’s Tools.

The right-wing for decades have been packing the courts in the land, at every level, with conservative judges and have been very good at it. Liberals working to get progressive judges elected, that’s not using the Master’s Tools.

I know everyone’s tired and frustrated and often demoralized, so I don’t blame any of us for being cynical. And it takes a tremendous amount of teeth-grinding patience and suppression of revulsion to look at all the destruction, cruelty, and chaos caused by the right-wing to individuals, society, and the environment and think, “Let’s learn from what they’re doing and maybe copy some of it.”

At the same time, we need to be able to distinguish which strategies are legitimately harmful and oppressive that we should not copy—sowing hatred, violating due process, using the marginalized as scapegoats, targeting the politically and socially weakest populations in society, spreading misinformation, doxxing people and sending bomb threats to their kids' schools, etc.,—and which ones are effective that we should be using.

Let me know your thoughts.

--

Vu’s book, Reimagining Nonprofits and Philanthropy, is out. Order your copy at Elliott Bay Book Company, Barnes and Nobles, or Bookshop. If you’re in the UK, use this version of Bookshop. If you plan to order several copies, use Porchlight for significant bulk discounts. Also, if you're buying 25 copies or more, I'll be glad to call in for a 50-minute discussion; please contact NWBspeaking@gmail.com.

The Ultimate Mango Layer Cake with Cardamom, Lime Curd, and Saffron Buttercream

Mango season doesn’t come with a warning. One week, the fruit is barely there at your local market, and the next, it’s everywhere: on every counter, in every container of canned pulp at the Indian grocery store, impossible to ignore. I made this mango layer cake for that very moment.

The recipe originally appeared in my column at the San Francisco Chronicle in July 2018 and has been a mainstay ever since. It’s one of those recipes I return to every year not because it’s easy (it isn’t, particularly) but because it is genuinely the fullest expression of mango I know how to build into a cake. Three components, three layers of flavor, one very satisfying result.

Why Three Parts Instead of One

Most mango cakes ask you to choose a lane: fresh fruit in the batter, a fruited frosting, or a filling. This one refuses to; it takes a very specific path, one with layers. The cake itself is a mango-cardamom cake made with freeze-dried mango ground directly into the flour. The filling is a bright, set mango lime curd. The exterior is a Swiss meringue buttercream bloomed with more freeze-dried mango and a thread of saffron. So yes, there’s mango in every layer of this cake.

Each layer has a purpose, and they each deliver. The cake brings a warm, floral mango note amplified by cardamom. The curd cuts through with acid and a jolt of concentrated fresh mango flavor. The buttercream ties everything together with a silky, aromatic sweetness that isn’t cloying. Together they read as mango from start to finish, but with enough movement in flavor and texture to stay interesting all the way to the last bite.

The Science Behind Freeze-Dried Mango in Cake Batter

This is the part most recipes skim over, and I want to explain why I am using freeze-fried mango. Freeze-dried fruit in cake batter is notoriously tricky. The reason: freeze-dried fruit is intensely hygroscopic, meaning it absorbs moisture aggressively. When you grind it and fold it into a standard all-purpose flour batter, it draws water from the surrounding structure, producing a gummy, dense crumb.

The fix, which I learned from my friend Stella Parks, is to use cake flour instead of all-purpose. Cake flour has a significantly lower protein content, which means less gluten development. That lower gluten network is more forgiving when the freeze-dried fruit starts competing for moisture, and the result is a crumb that stays tender and open rather than tight and gummy. Grinding the flour and freeze-dried mango together in a food processor before sifting twice is also key: it distributes the fruit evenly so you don’t get pockets of concentrated fruit fighting the surrounding batter.

The same logic applies to the buttercream. A Swiss meringue buttercream (I’m using Stella’s method), where egg whites and sugar are cooked together over a bain-marie before whipping, is a better base for freeze-dried fruit than an American-style buttercream. The cooked egg white structure is more stable, and the lower overall sugar content means the freeze-dried mango’s tartness can actually register.

Kesar or Alphonso: It Matters Which Mango You Use

For the curd, this layer cake recipe calls for canned Indian mango pulp. This is not a shortcut. It’s a deliberate choice. Both Kesar and Alphonso mangoes are available canned at most Indian grocery stores, and they have a depth of flavor, aroma, and natural sweetness that fresh supermarket mangoes rarely match outside of peak season. Alphonso (also known as Hapus) is the more aromatic of the two, with a richer, almost floral profile. Kesar is slightly more restrained but deeply sweet. Either works beautifully here. If you’re working with a pre-sweetened canned pulp, hold back on the sugar or skip it entirely and taste as you go.

Fresh mango works too if you’re in the middle of a good season and you have access to ripe, fragrant fruit. Purée the fruit in a food processor before use and then strain through a fine-mesh strainer to remove any fibers.

A Note on the Buttercream Yield

The recipe makes a full batch of Mango Saffron Buttercream, which is enough to frost two 8 in/20 cm layer cakes. If you’re making the mango lime curd and using it as filling, you’ll have frosting left over. Don’t consider this a problem. The buttercream keeps refrigerated in an airtight container for up to two weeks. To revive it, set the container over a pan of gently steaming water until the edges begin to soften, then transfer to a stand mixer and whip back to a creamy, spreadable consistency. It’s excellent on pound cake, piped onto cupcakes, or eaten from a spoon at room temperature.

Cardamom: Use Fresh Pods, Not Pre-Ground

The recipe specifies seeds from 3 to 4 green cardamom pods, about 3/4 tsp. Pre-ground cardamom is fine in a pinch, but it loses volatile aromatic compounds quickly once opened and ground. For a cake where cardamom is one of the primary flavor signals, using freshly cracked seeds and grinding them at home makes a real difference. You’re looking for a fine, even powder. A mortar and pestle works well, as does a small spice grinder.

The pairing of cardamom and mango isn’t arbitrary. Both share a set of aromatic compounds, and the cardamom acts as a kind of flavor amplifier here, extending the mango’s top notes without competing with them. It’s a combination that appears across South Asian sweets for exactly this reason.

Make-Ahead Notes for this Mango Layer Cake

I won’t lie to you, this is a project cake, and it’s better to approach it in stages:

The cakes can be baked up to two days ahead, cooled, wrapped tightly in plastic wrap, and refrigerated. They’re actually easier to trim and frost when cold.

The mango lime curd needs at least four hours of refrigeration to set, and overnight is better. Make it the day before.

The buttercream can be made ahead and refrigerated for up to two weeks (see above for how to revive it).

On assembly day: fill, crumb coat, chill for 30 minutes, then final frost. The whole thing keeps covered at room temperature for 3 to 4 days, or refrigerated for up to a week.

A Cake That Earns Mango Season

There’s a version of mango cake that exists mostly to announce itself. A little mango extract, some yellow food coloring, a gesture toward the fruit. This isn’t that. Every component here is pulling full weight. The freeze-dried fruit in both the cake and the buttercream, the curd with its hit of lime and concentrated pulp, the saffron threading through the frosting. It takes time. It’s worth it.

The full recipe is below.

The Ultimate Mango Cake

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This cake contains three parts: the mango cardamom cakes, the mango lime curd sandwiched between the cakes and the mango saffron buttercream that envelopes the entire assembly. You can make the curd and the buttercream ahead of time.

Freeze-dried fruit has excellent potential in desserts but can be tricky to use, especially in cakes. I reached out to my friend and pastry whiz Stella Parks, aka BraveTart, who recommends using cake flour over all-purpose, which prevents the gummy texture that often arises when using ground freeze-dried fruit in the cake batter. Over the years, her Swiss Meringue Buttercream has become my go-to frosting recipe because it’s not cloyingly sweet and has a light texture. It’s also highly amenable to adding freeze-dried fruit to incorporate more flavor and color. This recipe makes enough frosting to cover two 8 in/20 cm layer cakes. I’m giving you the recipe for a whole batch if you decide to skip the mango lime curd. This recipe is based on Stella Park’s Swiss Meringue Buttercream (via Serious Eats) which is my go-to buttercream frosting recipe.

This recipe first appeared in my column at The San Francisco Chronicle (July 2018)

• Yield: Two 8 in/20 cm round cakes

Ingredients

For the Mango Cardamom Cake

2 1/3 cups/280 g cake flour

1.7 oz/48 g unsweetened, unsulfured freeze-dried mango

2 tsp baking powder

seeds from 3 to 4 green cardamom pods (about 3/4 tsp)

¼ tsp fine sea salt

7.97 oz/226 g unsalted butter, at room temperature, cut into cubes plus extra butter to grease the baking pans

1 1/3 cups/265 g sugar

3 large eggs at room temperature

½ cup/120 g crème fraiche

½ cup/120 ml whole milk

For the Mango Lime Curd (makes about 1 1/4 cups/300 ml)

1 cup/240 ml canned Indian mango pulp pureed or the pulp from 1 medium ripe mango, pureed (See Notes)

2 oz/55 g unsalted butter, cubed

¼ cup/50 g sugar

Juice and zest of one lime

2 Tbsp cornstarch

2 Tbsp water

Mango Saffron Buttercream (makes about 6 cups/1.4 L)

1.7 oz/48 g unsweetened, unsulfured freeze-dried mango**

20 saffron strands

2/3 cup/160 ml egg whites (from about 5 to 6 large eggs)

1 2/3 cups/330 g sugar

¾ tsp fine sea salt

¼ tsp cream of tartar

1.24 lb/565 g unsalted butter, softened to 65F/18C

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Instructions

For the Mango Cardamom Cake

1. Preheat the oven to 350F/180C.
2. Grease and line two 8 in/20 cm, baking pans with a little unsalted butter and parchment paper cut to size. Keep aside until ready to use.
3. Using the metal blade in the bowl of a food processor, grind the cake flour, mango, baking powder, cardamom, and salt until you get a fine powder. Transfer the ground ingredients to a sheet of parchment paper and sift twice. Keep aside until ready to use.
4. Cream the butter for about 4 to 5 minutes using the stand mixer’s paddle attachment until light and fluffy over low speed. Add the sugar in a steady and slow stream from the side. Stop the mixer and scrape the sides of the bowl. Beat in the eggs, one at a time, scraping the bowl after adding each egg. The mixture will be pale yellow and fluffy in appearance. Add half the sifted dry ingredients to the bowl with the crème fraiche and whisk over low speed for 1 to 1 ½ minutes until combined. Scrape the sides of the bowl, add the remaining flour and the milk, and whisk over low speed for about 1 minute until combined and no visible flecks of dry ingredients can be seen. Divide the cake batter equally between the two prepared cake pans and bake in the preheated oven for about 30 to 45 minutes or until a skewer or knife comes out clean when inserted through the center of the cake and the tops are golden brown and firm to touch. Remove the cakes from the oven and allow to cool in the pan for 5 minutes. Using a knife, release the cakes from the sides of the pans, peel the parchment paper, and transfer the cakes to cool completely on a wire rack. The cakes can be prepared in advance, cooled, wrapped with cling film, and refrigerated for up to 2 days before frosting.

For the Mango Lime Curd

1. Place the mango, butter, sugar, lime juice, and zest in a medium, non-reactive stainless-steel saucepan and heat on medium-high, occasionally stirring with a silicone spatula for about 3 to 4 minutes. Once the mixture starts to boil, whisk the cornstarch and water in a small bowl and quickly whisk it into the mango mixture; whisk until the mixture begins to thicken in approximately 1 to 2 minutes. The final consistency will resemble a thick custard. Remove from heat, strain the mixture through a fine mesh sieve, and transfer to a storage container; press a piece of food-safe plastic wrap on the surface (to avoid forming a skin), and cover with a lid. Allow to cool completely and then refrigerate for at least 4 hours, preferably overnight, until completely chilled.

For the Mango Saffron Buttercream

1. Grind the mango to a fine powder using a food processor, transfer to a bowl, and keep aside.
2. Using a mortar and pestle, grind the saffron to a fine powder and keep aside until ready to use.
3. Fill a wide saucepan with about 1 ½ inches of water; the base of your mixing bowl must never touch the water. You can crumple a piece of aluminum foil to create a ring to prevent the bowl from touching the water. Heat the water on high until it starts to steam, then immediately reduce to a gentle simmer. Add the egg white, sugar, salt, cream of tartar, ground mango, and saffron to the stand mixer bowl and place the bowl over the saucepan of simmering water. Using a silicone spatula, stir the mixture and constantly scrape the sides of the bowl until the egg whites hold steady at 185F/85 C for about 10 to 12 minutes. Remove from heat and attach the bowl to the stand mixer. Whisk the mixture at high speed using the whisk attachment for about 10 minutes until the mixture becomes stiff and glossy and cools to about 90F/32C.
4. With the mixer still running, add about 2 Tbsp of butter at a time and continue to whisk until all the butter has been used. The buttercream will be ready when there are no visible flecks of butter and the mixture is thick, creamy, and soft at about 72F/22C. Preferably, use the buttercream immediately or refrigerate in an air-tight container or ziptop bag for two weeks. Place the buttercream over a pan of steaming water till the edges melt a little, remove from heat, and whip to soften before using.

Assembling the Cake

1. You can trim the top and edges of each cake with a sharp, serrated knife (I prefer trimming the tops off). Use the cakes only when completely cooled (preferably chilled); otherwise, the buttercream will melt.
2. Place a cake board or round on a turntable and place a tablespoon or two of buttercream in the center. Center the cake on the board; the buttercream will help glue the cake while frosting. Spread the mango lime curd on top of the cake, center the second cake on top, and transfer the cake to the refrigerator for 30 minutes.
3. Remove the cake from the refrigerator and coat the top and the sides with 1 cup of buttercream using an offset spatula to form a thin layer. Transfer the cake to the refrigerator and allow this “crumb coat” layer to firm up for about 30 minutes. Once this layer of buttercream has hardened, remove the cake from the refrigerator and coat it with buttercream using the offset spatula to get about a ¼ in/6 mm thick layer of frosting. Rotate the turntable while spreading the buttercream to get a smooth and even layer on the sides and the top of the cake. You can also create a pattern on top by swishing the side of your offset spatula to create a wavelike design on the surface of the buttercream. The cake can be served immediately or stored covered for up to 3 to 4 days at room temperature or refrigerated for up to 1 week in an airtight container.

Notes

• I prefer to use the unsweetened canned mango pulp from India, sold at most Indian grocery stores. The two common varieties are Kesar and Alphonso, each with their characteristic taste and aroma. I find it unnecessary to add sugar if the pulp is already pre-sweetened.

•  

• Author: Nik Sharma

If You Liked This Recipe, Try These

Mango Cardamom Flan The same cardamom and mango pairing in a silky, set custard. A simpler project with just as much flavor payoff.

Mango Lime Curd The filling from this cake, on its own. Spoon it over yogurt, toast, or anything that needs a hit of bright, concentrated mango.

Mango Coconut and Star Anise Ice Cream Mango season deserves more than one recipe. This one is creamy, aromatic, and surprisingly easy for a homemade ice cream.

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“Unc” is, apparently, the latest gamer term or gen Z slang to enter our common parlance. Articles have argued it originated recently, from young people, who use it as an insult to old people. Except that’s not what unc means, and that’s not where it came from.

Unc, short for uncle (though it’s also been argued, incorrectly, that it’s a shortening of “uncool”), can sometimes be used for gentle ribbing, but fundamentally it’s a term of respect. It’s not a term you bestow upon yourself, but instead a natural consequence of getting older and still showing up tell the youngbloods what’s up. You wanna know who’s really unc? Denzel Washington. That’s not because Denzel is uncool or out of touch, but because he has had a long and illustrious enough career to earn the respect of the younger generation.

The old black man who used to run a record shop that closed during COVID where I picked up a copy of the album The Name Of This Band Is Talking Heads is unc to me. My dad, the kind of guy who went down to our local college campus to give advice to students in the encampment for Palestine, is unc. The nice older man who sits on a folding chair outside of his apartment and sometimes asks me to grab him a water bottle from the bodega is unc. I love that guy. Evan Narcisse is unc, and not just because he insists on wearing salmon-colored pants, but because he’s acted as a mentor to me ever since I started working at Kotaku, and I’d never pass up a chance to playfully razz him a little bit. 

You’d never know the meaning of unc or its origins in black culture if you looked to mainstream media, and sometimes even independent media. The Guardian attributes this slang to “gen alpha” and cites examples such as people calling Timothee Chalamet “unc” for turning 30, which isn’t really that old. This was then cited as the definition in my colleague Keza MacDonald’s article about “unc games,” though the article has since been corrected to include a reference to the term’s origins in African American Vernacular English. This article also references an article written by my old boss at Vice’s Motherboard, Emmanuel Maiberg, who wrote about Marathon as a so-called “unc game.”

These false etymologies get reinforced through incurious reporting. 

“As you probably know, unc, short for uncle, is a way to jokingly refer to old, potentially out of touch people,” Maiberg writes. “As far as I can tell, it entered the video game discourse in the form of this meme in which a soyfaced unc excitedly points at the hall of fame of so-called ‘unc slop,’ or, in other words, games that old people say are very good.”

Though I love the writing of both MacDonald and Maiberg, they are both doing something that I have observed in the online fandom for video games for some time. Black people who play video games talk about the games in the terms that they are familiar with, then other, non-black people who play games pick up these terms and run with them. Suddenly, these slang terms become “gamer slang” rather than African American Vernacular English, and these false etymologies get reinforced through incurious reporting. 

It isn’t that MacDonald or Maiberg themselves are the appropriaters. In fact, it’s hard to blame them for not knowing the origins of a slang term that has been so thoroughly appropriated already. But this is a cycle I have watched for a long time, and reporters writing about slang terms black people have used for decades as fresh and new is the end result of that cycle. They get to be discoverers and explainers of something that has already been discovered and explained.

More broadly, I’ve also seen this happen to words and phrases like “chopped,” “clocked it,” “the tea,” “no cap,” and “it’s giving.” All of these are slang terms that originate from African American Vernacular English—“clocked it,” “the tea” and “it’s giving” come from black queer culture in specific—but have now been categorized as “gen Z slang.” I have heard some people start to refer to the habitual be, as in “it really do be like that,” as a “meme” and it makes me want to tear my fucking hair out. We been saying that! That one’s ours!

Non-black people want to take everything from us except the weight of our history.

Appropriation of black culture is nothing new to the internet or the world. When TikTok dances were all the rage, Taylor Lorenz tracked down the originator of the popular “renegade dance,” a black teenage girl who had been all but forgotten as original choreographer of the short routine. The teenage girl who originated the phrase “on fleek” was also almost immediately erased as the term gained popularity as slang. Even farther back than that, I remember my African American Studies professor in college showing us a book cover for a book of essays on this very topic that he felt was illustrative of the way that black culture is extracted from our communities and then commodified: On it was a photograph of a white teenage boy wearing baggy jeans with his boxers showing, which was a style that was popularized in 90s hip hop culture. The title of the book is Everything But The Burden, as in, non-black people want to take everything from us except the weight of our history.

The internet has hyper-accelerated this extractive process of appropriation. Black teenagers spend more time on social media of all kinds than their non-black peers, and thus have made black slang much more visible than ever before. It’s not a surprise that AAVE has become the language of the internet at large, but also, it’s become much harder to track the flow of language and place it in its proper context. Because of how quickly trends form and then dissolve on the internet—remember “mob wife” and “office siren”?—slang is also picked up, stripped from context, and then discarded at much faster rates than when I was younger. 

It’s also much more difficult to trace the origins of these pieces of terminology, given that much of their dissemination occurs in short form video content on a platform that actively censors its search results. Like Taco Bell does with food, platforms like TikTok and Twitter are incentivized to strip context from language, because then it can be flattened into a saleable product that can be co-opted by corporations. (You can see this in the saga of West Elm Caleb, which turned from a funny story about a bunch of people dating the same guy to a tweet from the Hellman’s Mayonnaise brand.)

Seeing unc stripped of its meaning actually makes me a little sad.

In 2021, Sydnee Thompson at BuzzFeed wrote about the tendency of the internet to extract and then decontextualize black slang, saying that media outlets often cement that decontextualization that is already extant through their reporting.

“When media outlets — including BuzzFeed — and individuals who discuss memes and popular culture reproduce instances of Black American cultural appropriation, they lend them more credibility,” Thompson wrote. “The BuzzFeed Style Guide includes entries for many of these slang terms … and there exists a question of whether we should note their AAVE origins when they come up in a story. Doing so would help put concepts in their proper context and make it more difficult for culture vultures to appropriate with impunity.”

At least in the cases of “on fleek” and the renegade dance, the appropriated trends were short-lived, flash in the pan ideas. But “unc” is something embedded more deeply into black culture, and seeing it stripped of its meaning actually makes me a little sad. If there’s anything insulting about being called unc, it’s the kind of insult that’s meant to bring people closer together, not reinforce an artificial boundary between generations. It’s a word you use for people who are actively in community with you, not people you are trying to shut out. 

I’d love to be unc someday—to be so respected by younger people that they know it won’t hurt my feelings to call me old. When I call someone unc, I don’t want anyone to think I’m insulting the generation older than me, or that becoming unc is in some way a bad thing. That’s not what it means or has meant to me, and I don’t want its meaning to be taken away.