8 J. Shaw obvious leeway for national authorities to protect either the interests of the state or societal cohesion.12 Of course, that sense of an infringement of sovereignty has largely emerged out of a narrow and restrictive interpretation of the idea of free movement as a unilateral track involving non-UK citizens (generally called ‘EU migrants’, not ‘EU citizens’) moving towards the UK, which has dominated in the Europhobic popular media. The choice to name certain social actions in terms of ‘immigration’ rather than ‘co-citizenship’ will always have consequences. Its impact should not be underestimated. It contributed to a strong perception in the UK – against the backdrop of an increasingly rigid immigration policy backed up by harsh enforcement actions against those falling foul of the law – that EU free movers are lucky, undeservedly lucky, migrants, doing better in the UK than UK citizens themselves, not least because the family reunion rules they benefit from are more generous than those applicable to UK citizens under UK law. On that count, they are not seen as sharing a status with UK citizens – i.e. that of EU citizen. And the sense that this status involves a twin track of mobility in both directions as well as the possibility to take common political action, e.g. in relation to European Parliament elections, is lost entirely. It could be said that national reactions (and the UK is hardly alone in this) to the constitutionalising case law in the sphere of ‘citizenship’, especially in relation to the status and rights of mobile EU citizens and their families (including third country nationals) resident in other member states, has lain behind the retrenchment of that same case law in recent years. Judges are not immune from political pressures. They read newspapers. The newest case law has become more respectful of the welfare sovereignty of the member states, and has stated clear limits to the dictum that the Court once pronounced, that there should be a ‘certain degree of solidarity’ amongst the member states when it comes to the question of which set of taxpayers should support which types of economically inactive, or less active, citizens. But while the CJEU has been busy in recent years stating that free movement is not free from limits, this move may have come too late for the UK. It is therefore perhaps surprising that we can see constitutional constraints on member state sovereignty continuing to accrete in relation to some of the choices that those states can make as regards the application of their domestic citizenship laws and its consequences, especially in the 12 Schmidt, S. (2017), ‘Extending Citizenship Rights and Losing it All: Brexit and the Perils of “Over-Constitutionalisation”, in Thym, D. above n.8, at 17–36.