From: Lewis F. Powell
To: Warren E. Burger
Copied: William H. Rehnquist, Sanda Day O'Connor
On: March 3rd, 1984
Action: Attached Material Relevant to a CaseThis may include memos about maps or pictures that will be incorporated in opinion; cover memo to circulation of some relevant non-case material for an opinion (e.g., newspaper article, related lower court opinion); memos may mention extra-court material that might be relevant (e.g., congressional hearings, a statute, other opinions that are somehow (perhaps tangentially) related to case at hand); circulation of clerk’s memo about case
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