From: William O. Douglas
To: Lewis F. Powell
Copied: Conference
On: April 11th, 1974
Action: Suggestion to Majority OpinionThis includes memo with broad statements including that a justice cannot join the opinion, cannot join a part of the opinion, does not agree with the opinion, or has continuing doubts with the opinion; memos that indicate that the author's change is not enough; memos that make suggestions for specific changes to majority opinion or that express reservations about some aspect of the majority opinion; this code is also given for suggestions to memorandum opinions by an assigned author
Action: UndecidedJustice states that he or she is undecided, including phrases like not ready to commit, need more time, not at rest, or to consider further