 Van Devanter was a staunch conservative, and he was replaced by the liberal Senator Hugo Black.Justice Owen Roberts, who had been highly influenced by the conservative bloc, now began adopting a more independent, middle-of-the-road jurisprudence.In the following term, the Supreme Court overruled 19 constitutional precedents, and seven legislative precedents—and "James v. Dravo Contracting Co." was one of the decisions which overruled precedent.