Justices Unbound

Justices Unbound - NYTimes.com:

Souter, still more discreet, nonetheless used his commencement address at Harvard last spring in part to describe reliance on the Framers’ original understanding as a “simplistic” method for interpreting the Constitution.

I read this as Souter calling out Scalia for the intellectual fraud he is. "Simplistic," is the diplomatic way of saying, "rigidly wed to a cynical, reactionary conservative political agenda dressed as legal theory."