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He won over not only Justice Neil Gorsuch, one of the more purely textualist justices, but Roberts as well, the conservative majority’s most ardent incrementalist voice.
Source: https://www.nytimes.com/2023/08/04/opinion/sunday/supreme-court-conservative.html
Writing in National Review, Andrew McCarthy relies heavily on this textualist argument to term Pence’s position “frivolous.”
Source: https://www.lawfareblog.com/how-much-can-speech-or-debate-clause-protect-mike-pence