This refers to a dissenting opinion draft, including dissents from denial of certiorari if in opinion form
Document 2
From: Lewis F. Powell
To: William H. Rehnquist
Copied: Conference
On: January 21st, 1975
Action: Join Dissent
Memos where a justice states that they join a dissenting opinion, including joining the dissent in part, joining a dissent from denial of cert, or joining a dissent at foot. The identity of the dissenting opinion author who receives the join is located in the JOINED variable.
