in several major cases, though Justice Kennedy had often sided with the liberal bloc. Roberts has also served as a swing vote, often advocating for narrow rulings and compromise among the two blocs of justices. Though the Court sometimes does divide along partisan lines, attorney and SCOTUSblog founder Tom Goldstein has noted that more cases are decided 9–0 and that the individual justices hold a wide array of views. The judicial philosophy of Roberts on the Supreme Court has been assessed by leading court commentators including Jeffrey Rosen and Marcia Coyle. Although Roberts is identified as having a conservative judicial philosophy, his vote in National Federation of Independent Business v. Sebelius (2012) upholding the constitutionality of the Patient Protection and Affordable Care Act (ACA) has caused reflection in the press concerning the comparative standing of his conservative judicial philosophy compared to other sitting justices of conservative orientation; he is seen as having a more moderate conservative orientation, particularly when his vote to uphold the ACA is compared to Rehnquist's vote in Bush v. Gore. Some commentators have also noted that Roberts uses his vote in high-profile cases to achieve a facially-neutral result that sets up for larger conservative rulings in the future. The Five Four Podcast went so far as to deem this maneuver the "Roberts Two-Step." Regarding Roberts' contemporaneous peers on the bench, his judicial philosophy is seen as more moderate and conciliatory than that of Antonin Scalia and Clarence Thomas. Roberts has not indicated any particularly enhanced reading of originalism or framer's intentions as has been plainly evident in Scalia's speeches and writings. Roberts' strongest inclination on the Court has been to attempt to re-establish the centrist aesthetics of the Court as being party neutral, in contrast to his predecessor Rehnquist who had devoted significant effort to promote a 'states-rights' orientation for the Court. Roberts' voting pattern reflecting his conservative judicial philosophy is most closely aligned to Samuel Alito on the Court, the latter of whom has also become associated with libertarian trends in the conservative judicial philosophy. After Ginsburg was replaced by Barrett, several commentators wrote that Roberts was no longer the leading justice. As the five other conservative justices could outvote the rest, he supposedly could no longer preside over a moderately conservative course while respecting precedent. Some said this view was confirmed by the court's 2022 ruling in Dobbs v. Jackson Women's Health Organization, which