Simplicity needs to looked at from a customer point of view. "Will this code make it simpler for the customer?" should be THE primary consideration. If we consider two equally valid choices (back-end code for example that is not exposed to customers) then the code that is easiest to maintain (or the code that is very easy to follow) is simplest. Think of the person maintaining your code as your customer. Too many people get suckered into writing "fancy" code, "elegant" code, "design pattern" code, what not. In my experience this practice almost always led to more issues than helped in any measurable way.