from workplace harassment, which were adopted in the wake of multiple sexual misconduct allegations against Judge Alex Kozinski. Garland's seven-year term as chief judge ended on February 11, 2020, with Judge Sri Srinivasan succeeding him. Garland continued to serve as an active member of the court until his retirement. Notable cases Garland is considered a judicial moderate and a centrist. Garland has been described by Nina Totenberg and Carrie Johnson of NPR as "a moderate liberal, with a definite pro-prosecution bent in criminal cases". Tom Goldstein, the publisher of SCOTUSblog, wrote in 2010 that "Judge Garland's record demonstrates that he is essentially the model, neutral judge. He is acknowledged by all to be brilliant. His opinions avoid unnecessary, sweeping pronouncements." Garland has a reputation for collegiality and his opinions rarely draw a dissent. As of 2016, Garland had written just fifteen dissents in his two decades on the court, fewer than his colleague Brett Kavanaugh, who wrote some 17 dissents over the previous decade. Administrative and environmental law Garland has tended to favor deference to regulatory agencies. For example, in In re Aiken County (2013), Garland dissented when the court issued mandamus ordering the Nuclear Regulatory Commission to process the Yucca Mountain nuclear waste repository license. In Americans for Safe Access v. Drug Enforcement Administration (2013), Garland joined a divided court upholding the DEA's classification of marijuana as a Schedule I drug. However, according to Goldstein, in a number of split decisions on environmental law Garland "favored contested EPA regulations and actions when challenged by industry, and in other cases he has accepted challenges brought by environmental groups." In Rancho Viejo, LLC v. Norton (2003), Garland found the arroyo toad was protected by the federal Endangered Species Act. Circuit Judge John Roberts dissented from the denial of rehearing en banc, writing that Congress's interstate commerce power cannot reach "a hapless toad that, for reasons of its own, lives its entire life in California." Criminal law and whistleblower protection While on the bench, Garland has shown a tendency to be deferential to the government in criminal cases, siding with prosecutors in ten of the fourteen criminal cases in which he disagreed with a colleague. For example, in United States v. Watson (1999), Garland dissented when the court concluded a prosecutor's closing argument was unduly prejudicial, objecting that a conviction should be reversed for only "the most egregious of these kind of