[FN1]. See, e.g., Hans Bader, Free Enterprise Fund v. PCAOB: Narrow Separation-of-Powers Ruling Illustrates That the Supreme Court Is Not “Pro-Business”, 2010 Cato Sup. Ct. Rev. 269, 269 (“Chief Justice John Roberts has often been depicted as an advocate of narrow rulings and a judicial philosophy of minimalism.”); Randall T. Adams, Note, Recent Development: Northwest Austin Municipal Utility District Number One v. Holder, 45 Harv. C.R.-C.L. L. Rev. 135, 135 (2010) (noting a canon of decisions by the Roberts Court “that might be fairly characterized as ‘minimalist”’).