Closed Chambers: The Rise, Fall, and Future of the Modern Supreme Court
Edward Lazarus
 The subject matter is familiar, but Closed Chambers argues that the breakdown had less to do with Warren Court precedents or abortion (the latter being exceptionally divisive, but rarely on the court's docket), but rather a fundamental split over the death penalty. This split was later widened over disagreements concerning civil rights litigation. Lazarus presents the zealotry of the abolitionists at the Legal Defense Fund, compounded by the actions of Justices Marshall and Brennan, as a major and mounting frustration even for the moderate Justices of the court. This frustration eventually lead even the center of the court - Justices White and Powell - to align with Justice William Rehnquist in seeing behind almost every repeat habeas petition the LDF's unwavering desire to abolish the death penalty, a position that even the moderate justices had rejected. If true, this would mean that an organization that set out to abolish the death penalty actually succeeded in making it more capricious, less well-overseen and more commonly used. Lazarus also argues that a tightly-organized network of conservative law clerks exercised substantial power over the Justices during his time as a law clerk.