From: William H. Rehnquist
To: Warren E. Burger
Copied: Conference
On: January 23rd, 1975
Action: Suggestion before Majority Opinion CirculatedJustice makes a suggestion or lays out position in the case before the majority opinion is circulated; discussion of issues before an opinion has been drafted; memo laying out other justice's position or describing how other justices’ have voted so far in the case; lays out position without directing it at a circulating opinion