Is it still called a "benchslap" when the judge directs it at a higher court rather than at a litigant? Whatever you'd call it, Judge Alison Burroughs of the Massachusetts District Court just issued a really good one, directed at the Supremes. Footnote 9 at pp. 27-28 is the most elegant and polite expression of the sentiment "hey, Supreme Court right-wing crazies, go fuck yourselves" that I've ever seen.
https://storage.courtlistener.com/recap/gov.uscourts.mad.283718/gov.uscourts.mad.283718.238.0_2.pdf

