 Jonathan Skrmetti, Chief Deputy Attorney General of Tennessee (which, with a number of other states, had filed an "amicus" brief on behalf of the employers in "Bostock"), observed that all three opinions in "Bostock" adopted a textualist approach.Echoing a comment made by Justice Elena Kagan in memorializing Justice Scalia, Skrmetti argued that "Bostock" shows "we really are all textualists now.