The issue recently was brought into the headlines by comments from Judge Andrew Napolitano, a Fox News analyst who said, “I think the president is dangerously close to totalitarianism. A few months ago he was saying the Congress doesn’t count. The Congress doesn’t mean anything. I am going to rule by decree and by administrative regulation. Now he’s basically saying the Supreme Court doesn’t count. It doesn’t matter what they think. They can’t review our legislation. That would leave just him as the only branch of government standing,” Napolitano said.