A “Conservative” Steps Down
On January 5, 1938, one of the Supreme Court’s last “strict constructionists” sent his resignation to the White House. Justice George Sutherland, whose uncompromising and frequently brilliant defense of the Constitution according to “the meaning the instrument plainly purports to convey” gave Franklin Roosevelt fits, was retiring. With relief, Roosevelt gave Sutherland’s seat to his Solicitor General, Stanley M. Reed.




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