In Trump v. United States, the actual distance between the majority and dissent is not vast. As Justice Barrett's concurrence points out, there is "substantial agreement" on certain points. Justice Sotomayor, in dissent, wrote that "The idea of a narrow core immunity might have some intuitive appeal, in a case that actually presented the issue." The disagreement really turns on how the Chief Justice chose to address other issues. To that end, the dissent chose very strong rhetoric to illustrate how misguided the majority opinion was.
Three rhetorical themes were repeated: abuse of power, personal gain, and corruption.
First, Justice Sotomayor referred three times to the concept of an "abuse of power":
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