It's a bit hyperbolic, sure, but he could easily pack the court, and if Roberts refused to swear in new justices, he could have him arrested. Obama should have done something similar with Garland: when McConnell refused to have a hearing, he should have given a speech about the Senate failing to complete its duties, ordered Roberts to swear Garland in, and then arrested Roberts if he protested the move (along with any other justices who tried to be stubborn). The president has men with guns, and SCOTUS does not, full stop.
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