From: William J. Brennan, Jr.
To: William O. Douglas
Copied: None
On: January 13th, 1970
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: May Write Memorandum OpinionA memo where a justice states that he or she may (or will likely) write a memorandum opinion