In re Summers
Encyclopedia
In re Summers, , is a 5-to-4 ruling by the United States Supreme Court which held that the First
and Fourtheenth
amendment freedoms of a conscientious objector
were not infringed when a state bar association
declined to admit him to the practice of law. The Illinois Constitution
required citizens to serve in the state militia in time of war, and all lawyers admitted to the bar were required to uphold the state constitution. Petitioner Clyde Summers
could not uphold that constitutional requirement due to his religious beliefs, and the Supreme Court upheld the denial
of his license of practice.
in accounting in 1939 and a J.D.
(cum laude) in 1942. While an undergraduate and law student, Summers became active in the Methodist Student Movement
and a believer in the social gospel
.
The United States
entered World War II on December 8, 1941. Summers, opposed to the use of force, declared himself a conscientious objector
. In 1942, Summers sought admission to the Illinois State Bar Association
, a prerequisite to the practice of law in the state of Illinois. The bar association
admitted he was of high moral character and exhibited excellent knowledge of the law, but in January 1943 denied him admission due to his conscientious objector status. Article 12 of the Illinois constitution required citizens to serve in the state militia in time of war, and all lawyers admitted to the bar were required to uphold the state constitution. However, Illinois had not drafted citizens into its state militia since 1864, Article 12 prohibited the drafting of conscientious objectors into the militia during peacetime, and the article permitted conscientious objectors to engage in work of significant national importance during war in lieu of military service. Nonetheless, Summers could not uphold the relevant constitutional requirement due to his religious beliefs, the bar association said.
With representation by the American Civil Liberties Union
, Summers sued, alleging that the bar association's actions had infringed his First and Fourteenth amendment rights. The Supreme Court of Illinois
held that 1) The courts had no jurisdiction over the issue, and thus no "case or controversy" existed under Article Three of the Constitution; and 2) The bar association had not discriminated against Summers on the basis of his religion but rather on the basis of his ability to uphold the military service section of the Illinois state constitution.
Summers appealed to the U.S. Supreme Court, and which granted certiorari
.
wrote the decision for the majority, joined by Chief Justice
Stone and Associate Justices Frankfurter
, Jackson
, and Burton
.
Reed first reviewed the case proceedings. Regarding the "case or controversy" aspect of the issue, Reed concluded that the admission of a lawyer to the bar was "a ministerial act which is performed by virtue of the judicial power, such as the appointment of a clerk or bailiff or the specification of the requirements of eligibility or the course of study for applicants for admission to the bar, rather than a judicial proceeding." However, under Osborn v. Bank of the United States
, 22 U.S. 738 (1824), because the judicial power is invoked, this allows a case to arise. But was there a controversy? For a controversy to exist, Reed said, it must follow the rule laid down in Muskrat v. United States
, 219 U.S. 346 (1911), which held that there must be actual disagreement and merely a hypothetical or potential disagreement. The record in In re Summers was incomplete and the response for petition of certiorari from the Illinois Supreme Court was oddly formed, leaving the issue of a controversy muddied. But the majority concluded that since the bar association committee had formed at the request of the Illinois Supreme Court and that court had acted on Summers' petition for relief, a true controversy existed. Without discussion, Reed furthermore asserted that denial of the right to practice law is a controversy, and a denial of that right by a state court triggers federal jurisdiction under Article Three of the U.S. Constitution.
In addressing Summers' conscientious objector claim, Reed denigrated Summers as a "religionist." Reed next asserted that the Fourteenth Amendment applied only to federal rights, not to purely state-guaranteed rights such as the right to practice law. But were Summers' First Amendment rights implicated? The majority concluded they were not. Reed asserted that the Illinois Supreme Court had not discriminated against Summers on the basis of his religion, but rather on his ability to uphold the Illinois Constitution's requirement that he serve in the militia:
Reed reviewed Summers' beliefs, noting that he had been certified a conscientious objector by the federal government, his beliefs were religiously founded, and his beliefs were sincerely held. But the Illinois Supreme Court had held that Summers would not serve in the militia if drafted, a claim which Summers had failed to challenge.
But these pacifist
religious beliefs were not protected by the First Amendment, Reed said. Relying on Hamilton v. Regents of the University of California
, 293 U.S. 245 (1934), he declared conscientious objection a "grace of Congressional recognition" and noted that the state of Illinois recognized no such rights.
The judgment of the Illinois Supreme Court was affirmed.
wrote a dissent, in which he was joined by Associate Justices Douglas
, Murphy
, and Rutledge
.
Black bluntly phrased the issue in terms starkly different than the majority's: "It has denied him a license on the ground that his present religious beliefs disqualify him for membership in the legal profession." Black reviewed Summers' qualifications for the bar, which were exceptionally high and otherwise undisputed. He also reviewed the foundation for Summers' deep religious convictions and opposition to the use of force.
Black found the majority's distinction between upholding the Illinois Constitution and discriminating against Summers' religious beliefs "circuitous". The Illinois Constitution, he said, would discriminate against entire religions, and could lead to the inescapable conclusion that the state could bar a conscientious objector from a wide range of constitutional protections merely by refusing to grant these protections to nonresistors. He wrote:
Black concluded that the Illinois Constitution's requirement was essentially a "test oath," an oath designed to test one's loyalty before any illegal act had actually occurred. But, relying on Cummings v. Missouri, 71 U.S. 277 (1867) and Ex parte Garland
, 71 U.S. 333 (1866), Black said that test oaths were anathema to the Constitution. "This feeling was made manifest in Article VI of the Constitution, which provides that 'no religious Test shall ever be required as a Qualification to any Office or public Trust under the United States.'" Illinois has the power to draft its citizens, and to punish them for refusing to serve in its militia, Black said, but it does not have the right to assume beforehand that Summers would take the bar association oath in bad faith and fail to fulfill it at some indeterminate time in the future. This thinking had been rejected by Associate Justice Oliver Wendell Holmes, Jr.
in his dissent in United States v. Schwimmer
, 279 U.S. 644 (1929), and by Chief Justice Charles Evans Hughes
in his dissent in United States v. Macintosh, 283 U.S. 605 (1931), and Black embraced their views. Finally, Black noted that Illinois had not imposed a draft since 1864 and that the majority was engaging in mere speculation about imposing one in the future. There was no violation of the oath, and no actual inability to uphold the state constitution, Black concluded. "[T] he probability that Illinois would ever call the petitioner to serve in a war has little more reality than an imaginary quantity in mathematics. I cannot agree that a state can lawfully bar from a semi-public position a well qualified man of good character solely because he entertains a religious belief which might prompt him at some time in the future to violate a law which has not yet been and may never be enacted."
Black would have overturned the decision of the Illinois Supreme Court.
The Court's ruling in In re Summers has been sharply criticized. Despite Justice Reed's stated respect for Summers' religious beliefs, Reed denigrated him as a "religionist" (someone whose beliefs are not thought through and imfirmly held). Reed also imposed his own theology on the Christian Bible
, openly criticizing Summers for misinterpreting its tenets and for practicing (rather than merely reading) it. One historian has said that "Justice Stanley Reed's majority opinion[is] lacking in anay analysis of the serious constitutional issue involved". A legal scholar has said that Reed's decision is "merely" that Illinois had the right to interpret its oath however it chose.
The dissents of Holmes in Schwimmer, Hughes in Macintosh, and Black in In re Summers have since become the majority view of the Supreme Court. Schwimmer and Macintosh were overruled in Girouard v. United States
, 328 U.S. 61 (1946). But even though the cases which formed the basis of the decision in In re Summers were disavowed, the Court reaffirmed Summers in 1950 in American Communications Association v. Douds
, 339 U.S. 382 (1950). In re Summers became the basis for the Court to uphold a number of loyalty oath cases during the Cold War
.
Summers later was admitted to the New York State Bar Association
and became one of the most respected legal educators in the United States. He was highly influential in the field of labor law, and was considered the nation's leading expert on union democracy. "What Louis Brandeis
was to the field of privacy law, Clyde Summers is to the field of union democracy," wrote Widener University School of Law
professor Michael J. Goldberg in the summer of 2010. "Summers, like Brandeis, provided the theoretical foundation for an important new field of law."
First Amendment to the United States Constitution
The First Amendment to the United States Constitution is part of the Bill of Rights. The amendment prohibits the making of any law respecting an establishment of religion, impeding the free exercise of religion, abridging the freedom of speech, infringing on the freedom of the press, interfering...
and Fourtheenth
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
amendment freedoms of a conscientious objector
Conscientious objector
A conscientious objector is an "individual who has claimed the right to refuse to perform military service" on the grounds of freedom of thought, conscience, and/or religion....
were not infringed when a state bar association
Bar association
A bar association is a professional body of lawyers. Some bar associations are responsible for the regulation of the legal profession in their jurisdiction; others are professional organizations dedicated to serving their members; in many cases, they are both...
declined to admit him to the practice of law. The Illinois Constitution
Illinois Constitution
The Constitution of the State of Illinois is the governing document of the state of Illinois. There have been four Illinois Constitutions; the fourth and current version was adopted in 1970.-History:...
required citizens to serve in the state militia in time of war, and all lawyers admitted to the bar were required to uphold the state constitution. Petitioner Clyde Summers
Clyde Summers
Clyde Wilson Summers was an American lawyer and educator who is best known for his work in advocating more democratic procedures in labor unions...
could not uphold that constitutional requirement due to his religious beliefs, and the Supreme Court upheld the denial
Denial of request
Denial of request is the refusal of one party to grant the request of another. Some acts that can be considered denial may include the refusal of a person or a group of people representing a company, organization, or government agency to provide what a client or one seeking to be a client has...
of his license of practice.
Background
Clyde Summers entered the University of Illinois at the age of 16, earning a Bachelor of ScienceBachelor of Science
A Bachelor of Science is an undergraduate academic degree awarded for completed courses that generally last three to five years .-Australia:In Australia, the BSc is a 3 year degree, offered from 1st year on...
in accounting in 1939 and a J.D.
Juris Doctor
Juris Doctor is a professional doctorate and first professional graduate degree in law.The degree was first awarded by Harvard University in the United States in the late 19th century and was created as a modern version of the old European doctor of law degree Juris Doctor (see etymology and...
(cum laude) in 1942. While an undergraduate and law student, Summers became active in the Methodist Student Movement
Wesley Foundation
A Wesley Foundation is a United Methodist campus ministry sponsored in full or in part by the United Methodist Church on a non-church owned and operated campus...
and a believer in the social gospel
Social Gospel
The Social Gospel movement is a Protestant Christian intellectual movement that was most prominent in the early 20th century United States and Canada...
.
The United States
United States
The United States of America is a federal constitutional republic comprising fifty states and a federal district...
entered World War II on December 8, 1941. Summers, opposed to the use of force, declared himself a conscientious objector
Conscientious objector
A conscientious objector is an "individual who has claimed the right to refuse to perform military service" on the grounds of freedom of thought, conscience, and/or religion....
. In 1942, Summers sought admission to the Illinois State Bar Association
Illinois State Bar Association
The Illinois State Bar Association is the largest voluntary state bar association in the country. Approximately 30,000 lawyers are members of the ISBA. Unlike some state bar associations, in which membership is mandatory, ISBA membership is not required of lawyers licensed to practice in...
, a prerequisite to the practice of law in the state of Illinois. The bar association
Bar association
A bar association is a professional body of lawyers. Some bar associations are responsible for the regulation of the legal profession in their jurisdiction; others are professional organizations dedicated to serving their members; in many cases, they are both...
admitted he was of high moral character and exhibited excellent knowledge of the law, but in January 1943 denied him admission due to his conscientious objector status. Article 12 of the Illinois constitution required citizens to serve in the state militia in time of war, and all lawyers admitted to the bar were required to uphold the state constitution. However, Illinois had not drafted citizens into its state militia since 1864, Article 12 prohibited the drafting of conscientious objectors into the militia during peacetime, and the article permitted conscientious objectors to engage in work of significant national importance during war in lieu of military service. Nonetheless, Summers could not uphold the relevant constitutional requirement due to his religious beliefs, the bar association said.
With representation by the American Civil Liberties Union
American Civil Liberties Union
The American Civil Liberties Union is a U.S. non-profit organization whose stated mission is "to defend and preserve the individual rights and liberties guaranteed to every person in this country by the Constitution and laws of the United States." It works through litigation, legislation, and...
, Summers sued, alleging that the bar association's actions had infringed his First and Fourteenth amendment rights. The Supreme Court of Illinois
Supreme Court of Illinois
The Supreme Court of Illinois is the state supreme court of Illinois. The court's authority is granted in Article VI of the current Illinois Constitution, which provides for seven justices elected from the five appellate judicial districts of the state: Three justices from the First District and...
held that 1) The courts had no jurisdiction over the issue, and thus no "case or controversy" existed under Article Three of the Constitution; and 2) The bar association had not discriminated against Summers on the basis of his religion but rather on the basis of his ability to uphold the military service section of the Illinois state constitution.
Summers appealed to the U.S. Supreme Court, and which granted certiorari
Certiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
.
Majority
Associate Justice Stanley Forman ReedStanley Forman Reed
Stanley Forman Reed was a noted American attorney who served as United States Solicitor General from 1935 to 1938 and as an Associate Justice of the U.S. Supreme Court from 1938 to 1957. He was the last Supreme Court Justice who did not graduate from law school Stanley Forman Reed (December 31,...
wrote the decision for the majority, joined by Chief Justice
Chief Justice of the United States
The Chief Justice of the United States is the head of the United States federal court system and the chief judge of the Supreme Court of the United States. The Chief Justice is one of nine Supreme Court justices; the other eight are the Associate Justices of the Supreme Court of the United States...
Stone and Associate Justices Frankfurter
Felix Frankfurter
Felix Frankfurter was an Associate Justice of the United States Supreme Court.-Early life:Frankfurter was born into a Jewish family on November 15, 1882, in Vienna, Austria, then part of the Austro-Hungarian Empire in Europe. He was the third of six children of Leopold and Emma Frankfurter...
, Jackson
Robert H. Jackson
Robert Houghwout Jackson was United States Attorney General and an Associate Justice of the United States Supreme Court . He was also the chief United States prosecutor at the Nuremberg Trials...
, and Burton
Harold Hitz Burton
Harold Hitz Burton was an American politician and lawyer.He served as the 45th mayor of Cleveland, Ohio, as a U.S. Senator from Ohio, and as an Associate Justice of the Supreme Court of the United States. He was known as a dispassionate jurist who prized equal justice under the law.-Biography:He...
.
Reed first reviewed the case proceedings. Regarding the "case or controversy" aspect of the issue, Reed concluded that the admission of a lawyer to the bar was "a ministerial act which is performed by virtue of the judicial power, such as the appointment of a clerk or bailiff or the specification of the requirements of eligibility or the course of study for applicants for admission to the bar, rather than a judicial proceeding." However, under Osborn v. Bank of the United States
Osborn v. Bank of the United States
Osborn v. Bank of the United States, 22 U.S. 738 , was a case set in the Banking Crisis of 1819, during which many banks, including the Second Bank of the United States, demanded repayment for loans which they had issued on credit that they did not have. This led to an economic downturn and a...
, 22 U.S. 738 (1824), because the judicial power is invoked, this allows a case to arise. But was there a controversy? For a controversy to exist, Reed said, it must follow the rule laid down in Muskrat v. United States
Muskrat v. United States
Muskrat v. United States, 219 U.S. 346 , is a case that appears in virtually every constitutional law casebook published, because of its delineation of the authority of United States federal courts to hear certain kinds of cases.-Facts:...
, 219 U.S. 346 (1911), which held that there must be actual disagreement and merely a hypothetical or potential disagreement. The record in In re Summers was incomplete and the response for petition of certiorari from the Illinois Supreme Court was oddly formed, leaving the issue of a controversy muddied. But the majority concluded that since the bar association committee had formed at the request of the Illinois Supreme Court and that court had acted on Summers' petition for relief, a true controversy existed. Without discussion, Reed furthermore asserted that denial of the right to practice law is a controversy, and a denial of that right by a state court triggers federal jurisdiction under Article Three of the U.S. Constitution.
In addressing Summers' conscientious objector claim, Reed denigrated Summers as a "religionist." Reed next asserted that the Fourteenth Amendment applied only to federal rights, not to purely state-guaranteed rights such as the right to practice law. But were Summers' First Amendment rights implicated? The majority concluded they were not. Reed asserted that the Illinois Supreme Court had not discriminated against Summers on the basis of his religion, but rather on his ability to uphold the Illinois Constitution's requirement that he serve in the militia:
- It is said that the action of the Supreme Court of Illinois is contrary to the principles of that portion of the First Amendment which guarantees the free exercise of religion. Of course, under our Constitutional system, men could not be excluded from the practice of law, or indeed from following any other calling, simply because they belong to any of our religious groups, whether Protestant, Catholic, Quaker, or Jewish, assuming it conceivable that any state of the Union would draw such a religious line. We cannot say that any such purpose to discriminate motivated the action of the Illinois Supreme Court.
Reed reviewed Summers' beliefs, noting that he had been certified a conscientious objector by the federal government, his beliefs were religiously founded, and his beliefs were sincerely held. But the Illinois Supreme Court had held that Summers would not serve in the militia if drafted, a claim which Summers had failed to challenge.
But these pacifist
Pacifism
Pacifism is the opposition to war and violence. The term "pacifism" was coined by the French peace campaignerÉmile Arnaud and adopted by other peace activists at the tenth Universal Peace Congress inGlasgow in 1901.- Definition :...
religious beliefs were not protected by the First Amendment, Reed said. Relying on Hamilton v. Regents of the University of California
Hamilton v. Regents of the University of California
Hamilton v. Regents of the University of California, was a decision of the Supreme Court of the United States that upheld the "right of California to force its university students to take classes in military training" and reiterated that "[i]nstruction in military science is not instruction in the...
, 293 U.S. 245 (1934), he declared conscientious objection a "grace of Congressional recognition" and noted that the state of Illinois recognized no such rights.
The judgment of the Illinois Supreme Court was affirmed.
Dissent
Associate Justice Hugo BlackHugo Black
Hugo Lafayette Black was an American politician and jurist. A member of the Democratic Party, Black represented Alabama in the United States Senate from 1927 to 1937, and served as an Associate Justice of the Supreme Court of the United States from 1937 to 1971. Black was nominated to the Supreme...
wrote a dissent, in which he was joined by Associate Justices Douglas
William O. Douglas
William Orville Douglas was an Associate Justice of the United States Supreme Court. With a term lasting 36 years and 209 days, he is the longest-serving justice in the history of the Supreme Court...
, Murphy
Frank Murphy
William Francis Murphy was a politician and jurist from Michigan. He served as First Assistant U.S. District Attorney, Eastern Michigan District , Recorder's Court Judge, Detroit . Mayor of Detroit , the last Governor-General of the Philippines , U.S...
, and Rutledge
Wiley Blount Rutledge
Wiley Blount Rutledge, Jr. was an American educator, lawyer, and justice of the Supreme Court of the United States.-Early life:...
.
Black bluntly phrased the issue in terms starkly different than the majority's: "It has denied him a license on the ground that his present religious beliefs disqualify him for membership in the legal profession." Black reviewed Summers' qualifications for the bar, which were exceptionally high and otherwise undisputed. He also reviewed the foundation for Summers' deep religious convictions and opposition to the use of force.
Black found the majority's distinction between upholding the Illinois Constitution and discriminating against Summers' religious beliefs "circuitous". The Illinois Constitution, he said, would discriminate against entire religions, and could lead to the inescapable conclusion that the state could bar a conscientious objector from a wide range of constitutional protections merely by refusing to grant these protections to nonresistors. He wrote:
- I cannot believe that a state statute would be consistent with our constitutional guarantee of freedom of religion if it specifically denied the right to practice law to all members of one of our great religious groups, Protestant, Catholic, or Jewish. Yet the Quakers have had a long and honorable part in the growth of our nation, and an amicus curiae brief filed in their behalf informs us that, under the test applied to this petitioner, not one of them, if true to the tenets of their faith, could qualify for the bar in Illinois. And it is obvious that the same disqualification would exist as to every conscientious objector to the use of force, even though the Congress of the United States should continue its practice of absolving them from military service. The conclusion seems to me inescapable that, if Illinois can bar this petitioner from the practice of law it can bar every person from every public occupation solely because he believes in nonresistance, rather than in force.
Black concluded that the Illinois Constitution's requirement was essentially a "test oath," an oath designed to test one's loyalty before any illegal act had actually occurred. But, relying on Cummings v. Missouri, 71 U.S. 277 (1867) and Ex parte Garland
Ex parte Garland
Ex parte Garland, , was an important United States Supreme Court case involving the disbarment of former Confederate officials.-Case:In January 1865 the Congress of the United States passed a law that effectively disbarred former members of the Confederate government by requiring a loyalty oath be...
, 71 U.S. 333 (1866), Black said that test oaths were anathema to the Constitution. "This feeling was made manifest in Article VI of the Constitution, which provides that 'no religious Test shall ever be required as a Qualification to any Office or public Trust under the United States.'" Illinois has the power to draft its citizens, and to punish them for refusing to serve in its militia, Black said, but it does not have the right to assume beforehand that Summers would take the bar association oath in bad faith and fail to fulfill it at some indeterminate time in the future. This thinking had been rejected by Associate Justice Oliver Wendell Holmes, Jr.
Oliver Wendell Holmes, Jr.
Oliver Wendell Holmes, Jr. was an American jurist who served as an Associate Justice of the Supreme Court of the United States from 1902 to 1932...
in his dissent in United States v. Schwimmer
United States v. Schwimmer
United States v. Schwimmer, 279 U.S. 644 , was a case decided by the Supreme Court of the United States.It concerned a pacifist applicant for naturalization who in the interview declared not to be willing to "take up arms personally" in defense of the United States...
, 279 U.S. 644 (1929), and by Chief Justice Charles Evans Hughes
Charles Evans Hughes
Charles Evans Hughes, Sr. was an American statesman, lawyer and Republican politician from New York. He served as the 36th Governor of New York , Associate Justice of the Supreme Court of the United States , United States Secretary of State , a judge on the Court of International Justice , and...
in his dissent in United States v. Macintosh, 283 U.S. 605 (1931), and Black embraced their views. Finally, Black noted that Illinois had not imposed a draft since 1864 and that the majority was engaging in mere speculation about imposing one in the future. There was no violation of the oath, and no actual inability to uphold the state constitution, Black concluded. "
Black would have overturned the decision of the Illinois Supreme Court.
Subsequent developments
Chief Justice Stone cast the deciding vote in the case. Although his vote contradicted the vast majority of his previous "freedom of religion" votes and decisions, Stone's reasons for deciding against free exercise in this case are not recorded.The Court's ruling in In re Summers has been sharply criticized. Despite Justice Reed's stated respect for Summers' religious beliefs, Reed denigrated him as a "religionist" (someone whose beliefs are not thought through and imfirmly held). Reed also imposed his own theology on the Christian Bible
Christian biblical canons
A Christian biblical canon is the set of books that a Christian denomination regards as divinely inspired and thus constituting the Christian Bible...
, openly criticizing Summers for misinterpreting its tenets and for practicing (rather than merely reading) it. One historian has said that "Justice Stanley Reed's majority opinion
The dissents of Holmes in Schwimmer, Hughes in Macintosh, and Black in In re Summers have since become the majority view of the Supreme Court. Schwimmer and Macintosh were overruled in Girouard v. United States
Girouard v. United States
Girouard v. United States, , was a case decided by the Supreme Court of the United States. It concerned a pacifist applicant for naturalization who in the interview declared not to be willing to fight for the defense of the United States. The case questioned a precedent set by United States v...
, 328 U.S. 61 (1946). But even though the cases which formed the basis of the decision in In re Summers were disavowed, the Court reaffirmed Summers in 1950 in American Communications Association v. Douds
American Communications Association v. Douds
American Communications Association v. Douds, 339 U.S. 382 , is a 5-to-1 ruling by the United States Supreme Court which held that the Taft–Hartley Act's imposition of an anti-communist oath on labor union leaders does not violate the First Amendment to the United States Constitution, is not an ex...
, 339 U.S. 382 (1950). In re Summers became the basis for the Court to uphold a number of loyalty oath cases during the Cold War
Cold War
The Cold War was the continuing state from roughly 1946 to 1991 of political conflict, military tension, proxy wars, and economic competition between the Communist World—primarily the Soviet Union and its satellite states and allies—and the powers of the Western world, primarily the United States...
.
Summers later was admitted to the New York State Bar Association
New York State Bar Association
The New York State Bar Association , with 77,000 members, is the largest voluntary bar association in the United States.-History:The State Bar was founded with a constitution that dates to 1877...
and became one of the most respected legal educators in the United States. He was highly influential in the field of labor law, and was considered the nation's leading expert on union democracy. "What Louis Brandeis
Louis Brandeis
Louis Dembitz Brandeis ; November 13, 1856 – October 5, 1941) was an Associate Justice on the Supreme Court of the United States from 1916 to 1939.He was born in Louisville, Kentucky, to Jewish immigrant parents who raised him in a secular mode...
was to the field of privacy law, Clyde Summers is to the field of union democracy," wrote Widener University School of Law
Widener University School of Law
Widener University School of Law is the ABA accredited law school of Widener University. The school, founded in 1971 as the Delaware Law School, operates on two of Widener's campuses, one in Wilmington, Delaware, and the other in Harrisburg, Pennsylvania....
professor Michael J. Goldberg in the summer of 2010. "Summers, like Brandeis, provided the theoretical foundation for an important new field of law."