PHH Corp. v. Consumer Fin. Prot. Bureau, No. 15-1177, 2018 WL 627055, at *88 (D.C. Cir. Jan. 31, 2018) (Kavanaugh, J., dissenting):
As compared to a single-Director independent agency structure, a multi-member independent agency structure—and its inherent requirement for compromise and consensus—will tend to lead to decisions that are not as extreme, idiosyncratic, or otherwise off the rails. Cf. Stephen M. Bainbridge, Why a Board? Group Decisionmaking in Corporate Governance, 55 Vand. L. Rev. 1, 12-19 (2002).
