Should the word 'established' in the Federal Advisory Committee Act be construed in accord with its plain meaning or more narrowly?

QUESTION PRESENTED The Federal Advisory Committee Act, 5 U.S.C. App. 2 §§ 1 16, imposes detailed reporting requirements on federal advisory committees. The Act defines “advisory committee” as including any committee “established” or “utilized” by a federal agency “in the interest of obtaining advice or recommendations for the President or one or more agencies or officers of the Federal Government.” 5 U.S.C. App. 2, § 3(2). In Public Citizen v. U.S. Dep’t of Justice, 491 U.S. 440 (1989), this Court held that the word “utilized” should not be construed in accordance with its “straightforward” and “literal” meaning but rather should be read narrowly—in part because assigning “utilized” its commonly understood meaning would raise considerable doubt regarding FACA’s constitutionality. 491 U.S. at 465-67. Relying on Public Citizen, the courts below held—in direct conflict with a decision of the Eleventh Circuit—that “established” should also be construed more narrowly than its ordinary meaning would suggest. The Question Presented is: Should the word “established,” as used in FACA, be construed in accord with its “plain” meaning (as the Eleventh Circuit held) or should be it construed more narrowly (as the Tenth Circuit held)?