are you sure it was written by a clerk? the justices all talk in interviews/etc as if they wrote them themselves. also to be clear, the dissent was only on the grants of immunity. they agreed with the majority in that personal acts can be prosecuted on a personal level.

and it's that personal non-immunity that's why trump is unlikely to escape much of these charges. in fact, the prosecutors were able to amend their complaint to be not in terms of official acts for almost all of it iirc.