Is this just a simple matter of how someone interprets the term "minimalism"?
Wasn't R.T. Jones known as the first guy who made the land fit his designs? And didn't he do this with heavy earth moving equipment? Couldn't you make a claim that all designers before him were minamilist?
But you could also break it down further among the pre-RTJ designers. Didn't the most early designers build on links land? But they tried to move inland, but the grass, soil, etc just didn't work. Then, Colt I think it was, started building in the Heathlands in England. Perhaps by RTJ and/or other modern designers this was minimalist, but back in his day didn't this require a lot of land clearing, etc?
Once again, how do you define the term depends how you answer the question.
I throw in once again, that I believe a true minimalist will build course that limits maintenance budgets, water usage, etc in addition to moving as little dirt as possible.