Not Activist Enough
As happens with pretty much any word the Left gets hold of, "activist judge" is about to lose all meaning. This is a really great read, wherein Jonathan H. Adler explains that Justice Brown is not activist enough.
As commonly understood, judicial activists are those judges who place their own policy preferences above the law in rendering opinions. Many would also argue it is particularly activist for a judge to strike down validly enacted laws or otherwise disregard legislative enactments without clear constitutional warrant. By this standard, Owen is arguably the least activist justice on the Texas supreme court — and far less activist than her critics would actually prefer.