On January 1, 2005, former Chief Justice William Rehnquist issued a year-end report [PDF] in which he defended the federal judiciary from political critiques. Chief Justice Rehnquist emphasized judicial independence as a means to "to administer the law fairly, without regard to public reaction," and expressed concern over calls to impeach federal judges "who issue decisions regarded by some as out of the mainstream." This year-end report was to be Rehnquist's last. He had not sat on the bench since late October 2004 due to treatment for thyroid cancer. John Roberts succeeded Rehnquist as Chief Justice in September 2005.