 The article noted that Payne had apparently violated federal law and the official Code of Conduct for U.S. judges, which "explicitly prohibit judges from sitting on cases involving companies in which they own stock—no matter how small their holdings".This prohibition, established as federal law in 1974 by Congress after the Watergate scandal, is intended to uphold the integrity of the judicial system.Scholars of legal ethics such as professor Leslie W. Abramson, of University of Louisville's law school, and Stephen Gillers, of New York University School of Law, noted that the law was clear and that the judge should have recused himself from these cases where he had a conflict.