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Howell Heflin

Howell Thomas Heflin (June 19, 1921 – March 29, 2005) was an American lawyer, jurist, and politician who represented Alabama as a Democrat in the United States Senate from 1979 to 1997. Born in Poulan, Georgia, Heflin graduated from Birmingham-Southern College in 1942 and the University of Alabama School of Law in 1948. During World War II, he served as a first lieutenant in the United States Marine Corps from 1942 to 1946, participating in invasions of Bougainville and Guam in the Pacific Theater, where he was wounded twice and awarded the Silver Star for valor and two Purple Hearts. After the war, he practiced law in Tuscumbia, Alabama, before being elected Chief Justice of the Alabama Supreme Court in 1970, serving from 1971 to 1977 and spearheading reforms to the state's antiquated judicial system. In the Senate, Heflin chaired the Senate Judiciary Subcommittee on Juvenile Justice and was known for his conservative stances on issues like crime and defense, often aligning with Republican initiatives despite his Democratic affiliation. A nephew of former Alabama Senator James Thomas Heflin, he retired in 1997 after three terms, leaving a legacy as a principled Southern Democrat who prioritized judicial reform and military valor.

Early Life and Education

Childhood and Family Background

Howell Thomas Heflin was born on June 19, 1921, in Poulan, Worth County, . His father, Marvin Heflin (also known as Marvin Rutledge Heflin), served as a Methodist minister, while his mother, Louise Strudwick Heflin, had worked as a teacher prior to raising the family. The Heflin family relocated frequently during his early years, moving between rural communities in and to accommodate his father's pastoral assignments. After settling in , Heflin spent the majority of his childhood in the state, immersed in its public school system amid a backdrop of Southern agrarian life. Heflin hailed from a politically connected lineage; he was the nephew of James Thomas "Cotton Tom" Heflin, a U.S. Senator from who served from 1920 to 1931, as well as the cousin of educator and reformer Julia Strudwick Tutwiler and the grandnephew of Congressman Robert Stell Heflin. These familial ties linked him to 's early 20th-century political and educational establishment, though no direct influence on his childhood activities is documented in primary records.

Academic and Early Professional Training

Heflin graduated from Colbert County High School in Leighton, Alabama, after completing his primary and in public schools. He then enrolled at Birmingham-Southern College in , in 1938, majoring in history and , and received a Bachelor of Arts degree in 1942. Following service, Heflin attended the School of Law in Tuscaloosa, earning a (or LL.B.) degree in 1948; during this period, he also taught courses at the . Admitted to the bar in 1948, he commenced private legal practice in , his hometown in Colbert County, focusing initially on general civil and trial work. In his early professional years, Heflin built experience through courtroom advocacy and local legal engagements, supplementing his practice with adjunct faculty roles at the and the , which honed his expertise in and procedure. By the mid-1950s, his reputation in Alabama legal circles had grown, evidenced by leadership positions such as presidency of the Alabama Trial Lawyers Association in 1963, reflecting advanced training in trial advocacy and professional standards.

Military Service

World War II Enlistment and Combat Experience

Howell Heflin served as an officer in the United States Marine Corps from 1942 to 1946, participating in combat operations in the Pacific Theater. Assigned to the Assault Platoon of Company A, 1st Battalion, 9th Marines, 3d Marine Division, he took part in the Bougainville campaign in the Solomon Islands. On November 25, 1943, during the Battle of Piva Forks on , Heflin led his platoon under intense enemy mortar and automatic weapons fire through dense jungle terrain. Despite close-range grenades and gunfire, he skillfully maneuvered his troops and exposed himself to direct the attack, contributing to the defeat of the enemy position and achievement of the company's objective. For this action, he was awarded the for conspicuous gallantry and intrepidity. Heflin also fought in the invasion of in 1944, where he sustained wounds requiring medical attention. He received two for wounds suffered during his service, reflecting the hazards of amphibious assaults and island-hopping campaigns against Japanese forces.

Awards and Post-War Transition

Heflin received the for gallantry in action as a in the , , during operations in the Pacific Theater of . He earned two medals for wounds incurred while participating in the invasions of and . These decorations recognized his valor and sacrifices amid intense combat against forces. Discharged from the in 1946 with the rank of major, Heflin transitioned to civilian life by enrolling in the School of Law. He completed his degree there in 1948, marking the beginning of his legal career in . This period of study and subsequent entry into private practice laid the foundation for his future roles in law, , and .

Legal and Judicial Career in Alabama

Private Practice and Initial Public Roles

Following his discharge from the in 1946 and graduation from the School of Law with an LL.B. in 1948, Howell Heflin established a practice in , where he focused on trial work and built a reputation as a prominent in the Shoals region. He maintained this practice continuously from 1948 until 1971, when he assumed the role of of the Supreme Court, handling cases in civil and criminal matters typical of a in a small-town setting. Heflin's involvement in initial public roles centered on leadership within Alabama's legal community rather than elected political office. In 1949, he became the founding president of the Alabama Law School Alumni Association, serving through 1951 and fostering ties between the university and its graduates. He later ascended to the presidency of the Alabama Trial Lawyers Association from 1963 to 1965, advocating for trial attorneys' interests amid evolving state legal standards. These positions paved the way for further influence, as Heflin served as president of the Alabama State Bar Association from 1965 to 1966, during which he pushed for professional reforms including ethical standards and bar integration efforts post-Brown v. Board of Education. Concurrently, from 1964 to 1966, he presided over the Alabama Law School Foundation, supporting legal education initiatives. By 1969, Heflin chaired the Alabama Ethics Commission until 1971, overseeing disciplinary matters and contributing to the modernization of attorney conduct rules in the state. These roles established his stature as a reform-minded figure in Alabama jurisprudence prior to statewide elected office.

Chief Justice of the Alabama Supreme Court

Howell Heflin was elected Chief Justice of the Alabama Supreme Court in the November 1970 , assuming office on January 18, 1971, and serving a single six-year term until January 17, 1977. During his tenure, Heflin prioritized to address inefficiencies in Alabama's fragmented and outdated court system, inherited from the 1901 state constitution. He advocated for legislative changes, including the unification of trial courts, merit selection for judges in some circuits, and improved administrative oversight, which culminated in the adoption of the Judicial Article in 1973 as Amendment 328 to the constitution. This reform measure streamlined court operations by consolidating jurisdictions, reducing backlog—such as clearing all cases by October 1972—and establishing a unified judicial and administrative under the chief justice's direction, marking a foundational modernization of Alabama's . Heflin also authored significant opinions addressing judicial authority, rights, criminal procedural standards, and in legal contexts, contributing to precedents that expanded protections in these domains while upholding state constitutional limits.

U.S. Senate Elections and Tenure

1978 and Subsequent Campaigns

In the 1978 Democratic primary for the U.S. Senate seat vacated by retiring Senator , Heflin competed against a crowded field including and Paul Hubbert, advancing to a runoff against Baxley, whom he defeated by emphasizing his judicial experience and conservative credentials as former of the . In the general on November 7, Heflin prevailed over nominee James D. Martin, a former U.S. Representative, capturing 400,052 votes (55.2 percent) to Martin's 316,265 votes (43.8 percent), with minor candidates taking the remainder; the victory reflected Alabama's entrenched Democratic dominance despite national gains. Heflin secured re-election in 1984 amid President Ronald Reagan's statewide landslide, first winning the Democratic primary on September 4 against token opposition, then defeating Albert Lee Smith, a former U.S. Representative known for his , in the general election on November 6 with 860,535 votes (57.1 percent) to Smith's 644,341 votes (42.9 percent). His campaign highlighted seniority in securing federal funds for infrastructure and , distancing himself from national Democratic figures while appealing to rural and working-class voters wary of party shifts. For his 1990 re-election, Heflin faced no serious and won the November 6 general election against Republican businessman James S. Parker with 590,504 votes (60.0 percent) to Parker's 390,589 votes (39.6 percent), bolstering his margin through endorsements from agricultural interests and a focus on defense contracts benefiting Alabama's military bases. Heflin's consistent electoral success stemmed from his reputation as a advocate and committee influence, though he opted not to seek a fourth term in 1996 amid perceptions of Democratic vulnerability in the South.

Committee Assignments and Leadership Roles

Upon entering the Senate in January 1979, Heflin was assigned to the Committees on , Nutrition, and Forestry; Commerce, Science, and Transportation; and the , reflecting his background in law, agriculture interests in , and prior judicial experience. He also joined the Select Committee on Ethics as its chairman in November 1979, an unusual role for a senator, where he oversaw investigations into senatorial conduct. Heflin chaired the during the 96th Congress (1979–1981) and again from the 100th through 102nd Congresses (1987–1993), presiding over high-profile probes including the 1991 hearings involving senators' ties to financier . In this capacity, he emphasized enforcement of ethical standards, leading prosecutions such as that against Senator Harrison Williams in the scandal. On the Judiciary Committee, Heflin served throughout his tenure, participating in confirmation hearings for judicial nominees and contributing to legislation on civil justice reform, though he did not hold a subcommittee chairmanship. His Agriculture Committee role focused on issues affecting Southern farmers, including commodity programs and , aligning with Alabama's economic priorities. Similarly, on , he addressed transportation and trade matters pertinent to the state's ports and industries. Additionally, Heflin served on the special investigating the Iran-Contra affair in 1987, reviewing executive branch actions in arms sales and funding of Nicaraguan rebels. These assignments positioned him as a moderate influencing key policy areas without ascending to full committee chairmanships beyond Ethics.

Legislative Positions and Key Actions

Economic and Regional Issues

Heflin served on the Committee on Agriculture, Nutrition, and from 1981 onward, where he advocated for policies supporting Alabama's agricultural sector, including subsidies for and producers that formed a significant portion of the state's economy. These efforts aimed to stabilize rural incomes amid fluctuating prices and competition, reflecting Alabama's reliance on row crops in the Black Belt region, which accounted for over 20% of the state's agricultural output in the 1980s. In regional development, Heflin prioritized federal investments in Huntsville's industry, securing appropriations for NASA-related projects and defense contracts that bolstered employment in , where the sector employed tens of thousands by the 1990s and contributed substantially to the area's GDP growth from military and space programs. He also introduced S. 2051 in 1982 to reinstate the , enabling businesses to claim credits on qualifying expenditures to encourage capital investment and job creation during economic downturns. Heflin endorsed a in the early 1990s, arguing it would curb federal spending and deficits exceeding $200 billion annually, thereby fostering long-term economic discipline without raising taxes, a position aligned with amid 's interest in reduced national debt burdens on regional borrowing. His votes against measures, such as limiting in cases in 1996, preserved broader legal avenues for plaintiffs in industrial disputes, though critics contended this hindered business expansion by increasing litigation risks.

National Security and Foreign Policy

Howell Heflin served on the Senate Armed Services Committee throughout his tenure from 1979 to 1997, influencing defense policy and military readiness. As a Marine Corps veteran awarded the and , Heflin advocated for robust national defense, reflecting a conservative stance shaped by his experience and the context. Heflin aligned with President on defense buildup efforts, earning praise for transcending partisan lines on military strengthening. He consistently opposed reductions in defense spending, voting against measures to freeze or cut military budgets in favor of maintaining superiority and modernization. For instance, in key votes during the 1990s, Heflin supported allocations prioritizing readiness over non-defense discretionary cuts. On foreign policy, Heflin endorsed decisive military action, including voting in favor of the Authorization for Use of Military Force Against Resolution on January 12, 1991, authorizing President to use force in the Persian Gulf War. In his October 1, 1996, valedictory address titled "Some Departing Thoughts on Our National Defense and Foreign Policy," Heflin emphasized sustained vigilance against emerging threats post-Cold War, urging balanced commitments to deterrence and international stability. His positions prioritized empirical assessments of global risks over budgetary constraints, consistent with causal analyses of power projection's role in preserving U.S. security.

Civil Rights and Social Issues

Heflin supported the 1982 extension and strengthening of the Voting Rights Act, serving as one of the pivotal Democrats alongside Robert Dole in negotiating the compromise that secured its passage on August 5, 1982, by a vote of 85-8. He also voted in favor of the National Voter Registration Act of 1993, known as the Motor Voter law, which passed the on March 17, 1993, by a vote of 64-36, aiming to increase voter participation through simplified registration processes. In the 99th Congress (1985-1986), Heflin's voting record on civil rights measures aligned with Democratic priorities on several key bills, including support for fair housing amendments and anti-discrimination provisions, though he occasionally diverged on procedural matters. Similarly, during the 100th Congress (1987-1988), he backed legislation restoring civil rights enforcement weakened by court rulings, such as the Civil Rights Restoration Act. On , Heflin's Senate Judiciary Committee role involved probing nominees' views without endorsing quotas; for example, during Antonin Scalia's 1986 confirmation, he elicited Scalia's qualified support for programs aiding the disadvantaged, reflecting Heflin's emphasis on merit over racial preferences in federal policy. He employed minority staffers in his office, a practice noted as advancing diversity in Senate operations amid Alabama's historical context. Regarding social issues, Heflin opposed rights, voting against federal funding expansions and supporting state-level restrictions, consistent with his conservative Southern Democratic stance that prioritized fetal protection over reproductive autonomy claims. He resisted most initiatives, including opposition to the 1993 Brady Handgun Violence Prevention Act's waiting period provisions, favoring Second Amendment interpretations that limited federal overreach on firearms ownership. Heflin's positions on issues like gay rights remained traditional, aligning with opposition to federal recognition of same-sex partnerships during his tenure, though specific votes were limited by the era's legislative focus. Overall, his record reflected a blend of support for institutional civil rights protections and resistance to expansive , shaped by Alabama's electorate and post-segregation political realignments.

Controversies and Criticisms

Associations with Segregationist Legacy

Howell Heflin descended from a politically prominent family with deep ties to segregationist ideologies, most notably through his great-uncle, J. Thomas "Cotton Tom" Heflin, who served as a U.S. Senator from from 1921 to 1931 and was renowned for his unyielding defense of . Cotton Tom Heflin delivered fiery speeches in opposing anti-lynching legislation, Catholic political influence, and any erosion of , positioning himself as a leading voice for in the post-World War I era. This familial legacy shadowed Howell Heflin's public career, as 's Democratic establishment in the mid-20th century remained steeped in the residues of the state's one-party system, which had long accommodated segregationist sentiments to maintain power. In his early professional life following service, Heflin, then a Tuscumbia attorney and circuit solicitor, publicly denounced the in a 1946 address to delegates, calling for efforts to "drive the KKK out of business" amid its resurgence in the Shoals region tied to racial tensions. This stance marked an early divergence from the violent enforcement mechanisms of , though Alabama's legal and political frameworks under which Heflin operated as a state from 1948 to 1952 enforced de jure separation in public facilities and schools until federal interventions in the 1960s. Critics later pointed to Heflin's silence or alignment with Democratic norms during the height of to (1954), as Southern politicians, including Alabama governors, mobilized against integration without widespread public repudiation from the bench or bar. As of the Alabama Supreme Court from 1971 to 1977, Heflin presided over a navigating the aftermath of civil rights upheavals, including desegregation mandates, but his tenure drew scrutiny for upholding aspects of the state's 1901 constitution—drafted explicitly to disenfranchise Black voters and entrench —which contained provisions limiting federal oversight on racial matters until reforms in the 1970s. During his 1978 U.S. Senate campaign, opponents invoked the Heflin name's historical baggage to question his commitment to post- reconciliation, though Heflin emphasized bipartisan and opposition to George Wallace's lingering segregationist appeals. Heflin's Senate record from 1979 to 1997 included support for civil rights extensions, such as voting rights renewals, and hiring staffers, earning praise from some quarters for transcending Southern stereotypes, yet it faced distrust from African American leaders who viewed his conservative Democratic roots—forged in a pre-1965 —as inherently compromised by the era's systemic biases. In a 1996 farewell address, Heflin expressed pride in civil rights progress under his watch, but declining voter turnout in his final re-election bid underscored persistent associations with the state's segregationist past, contributing to his retirement amid shifting party alignments.

Confirmation Hearings and Nominee Scrutiny

As a senior member of the Committee from 1979 to 1997, Howell Heflin played a pivotal role in evaluating federal judicial nominees, emphasizing judicial temperament, impartiality, and adherence to precedent over ideological alignment. Heflin, drawing on his experience as of the , often probed nominees' past statements, writings, and potential biases during hearings, viewing the process as essential to ensuring fair adjudication rather than mere partisan endorsement. He supported the majority of Reagan's judicial appointees—voting yes on all but two of 325 nominations by 1987—but reserved opposition for those raising "reasonable doubts" about neutrality, particularly in civil rights contexts. Heflin's scrutiny drew national attention in the 1986 hearings for U.S. Attorney ' nomination to a federal district judgeship in . Initially sponsoring Sessions, a fellow Alabaman, Heflin shifted after testimony alleging racial insensitivity, including Sessions' prosecution of civil rights activists and comments perceived as hostile to voting rights enforcement. On June 5, 1986, Heflin voted against , stating the "overriding inquiry" was Sessions' capacity for fairness, which he deemed uncertain based on evidence of potential prejudice against minorities. His decisive no vote, as the committee's swing member, blocked Sessions' advancement, marking a rare rebuke of a Reagan nominee and highlighting Heflin's prioritization of evidentiary concerns over regional loyalty. In confirmations, Heflin opposed Robert Bork's 1987 nomination, joining the Judiciary Committee's 9-5 rejection recommendation after questioning Bork's originalist views as risking departure from established precedents on privacy and equal protection. He later voted against in 1991, announcing opposition on September 26 following hearings marked by Thomas' evasive responses to queries on philosophy, past speeches critiquing welfare programs, and allegations of workplace misconduct raised by . Heflin, who interrogated Thomas on these points—including Hill's testimony—cited inconsistencies between Thomas' record and professed judicial restraint as disqualifying, despite his general support for conservative justices. These stances positioned Heflin as a moderate Southern whose independent assessments influenced outcomes, though critics from conservative circles accused him of ideological filtering under the guise of impartiality scrutiny.

Partisan Independence and Party Tensions

Heflin, a Democrat from , frequently demonstrated partisan independence through conservative voting patterns that diverged from the national Democratic Party's liberal wing, particularly on fiscal, defense, and social issues. His record included opposition to most measures and a pro-life stance against funding, positions that aligned more closely with priorities and drew rebuke from party liberals who viewed such votes as undermining Democratic unity. For instance, Heflin supported aspects of President Ronald Reagan's defense buildup during the , reflecting his emphasis on over party-line spending restraint favored by some Democrats. These divergences contributed to tensions within the Democratic , as Heflin's Boll Weevil-style conservatism—common among —prioritized regional interests like agriculture subsidies and military bases in over broader party agendas on social welfare expansion. Critics within the party, including national figures, occasionally faulted him for insufficient loyalty, especially during the when he opposed key elements of Clinton's initiatives, such as certain tax hikes and regulatory expansions, voting conservatively in ways comparable to some Republicans. This independence fostered working relationships across the aisle, including with GOP leaders, but exacerbated intra-party friction amid growing national polarization, where like Heflin faced pressure to conform or risk marginalization. Heflin's approach extended to judicial matters, where he scrutinized nominees rigorously regardless of party, as seen in his pointed questioning during Thomas's 1991 confirmation hearings, prioritizing perceived inconsistencies over solidarity. Such actions underscored his commitment to institutional norms over blind party fealty, though they sometimes alienated Democratic allies expecting unified opposition to Republican appointees. Overall, Heflin's tenure highlighted the challenges of maintaining Southern Democratic viability in an era of realigning politics, balancing state conservatism with national party demands until his 1997 retirement.

Post-Senate Life and Death

Retirement Activities

Following his retirement from the U.S. Senate on January 3, 1997, Howell Heflin returned to his longtime home in , where he focused on personal and community-oriented pursuits. He spent significant time with family and friends, reflecting on his long public career that spanned over 25 years in service to . Heflin engaged in selective professional activities, including collaboration with biographers to document his life story, participation in lobbying efforts aligned with his prior legislative interests, and delivery of occasional political speeches. He also served as distinguished senator-in-residence at the , sharing insights from his Senate experience with students and faculty. In a demonstration of ongoing commitment to Alabama's youth, Heflin anonymously donated more than $1 million to establish a scholarship foundation that funded college education opportunities for deserving young people across the state. These efforts underscored his continued, albeit quieter, service to his community until his death in 2005.

Death and Immediate Tributes

Howell Thomas Heflin died of a heart attack on March 29, 2005, at the age of 83, while a patient at Memorial Hospital in , following complaints of stomach pain. He had resided in , since retiring from the in 1997. A public memorial service was held on April 3, , at 2:00 p.m. in the Deshler High School Auditorium in Tuscumbia, drawing attendees including former colleagues who eulogized Heflin's character and service. Longtime aide Steve Raby delivered the , maintaining composure while recounting Heflin's personal and professional life, after which Raby broke down emotionally. Former Congressman Browder described the event as a "sunny" Southern memorial befitting Heflin's demeanor. The U.S. Senate responded swiftly with S. Res. 93, introduced by Senators , , , and , and agreed to on April 4, 2005, expressing "profound sorrow" at Heflin's passing and commending his Marine Corps service (including the ), tenure as Chief Justice from 1971 to 1977, three terms as Senator representing for 18 years, and chairmanship of the Select Committee on Ethics during the 96th and 100th through 102nd Congresses. Senator offered a floor tribute lamenting the loss of a "dear friend and former colleague," emphasizing Heflin's integrity. News accounts highlighted Heflin's widespread praise for his gentlemanly demeanor across political lines.

Legacy and Impact

Contributions to Judicial Reform

As Chief Justice of the Alabama Supreme Court from 1971 to 1977, Heflin spearheaded the modernization of Alabama's judicial system, which prior to reform was fragmented, inefficient, and marred by , with non-attorney judges common in lower courts. He led the effort to pass the Judicial Article (Article VI) as a in 1973, the first major revision to Alabama's 1901 , establishing a unified judicial system that centralized administration under the , mandated licensed attorneys for all judges, and introduced processes for appellate judges to enhance qualifications and reduce political . Implementation followed with the Judicial Article Implementation Act signed by Governor on October 10, 1975, creating structured circuits and districts while improving case management and judicial efficiency. These reforms transformed Alabama's courts into a co-equal branch of government, aligning them with national standards and earning Heflin acclaim for consultative leadership that built bipartisan support despite resistance from entrenched interests. In the U.S. from 1979 to 1997, as a member and later ranking member of the Judiciary Committee, Heflin extended his reform focus to the federal level, advocating for structural changes to address caseload burdens and inefficiencies. On July 29, 1981, he introduced S. 1529, the National Court of Appeals Act, proposing an intermediate appellate body to handle nationwide review of circuit conflicts and petitions, aiming to alleviate the U.S. 's backlog without expanding its size. Though the bill did not pass, it contributed to ongoing debates on federal appellate capacity. Heflin also sponsored S. 1530 to create a Federal Courts Study Commission and Advisory Council for long-term evaluation and reform of the federal judiciary, including selection processes, and in 1992 introduced recommendations from the Federal Courts Study Committee to streamline operations and address jurisdictional overlaps. His efforts modernized aspects of federal judicial administration, such as improved nomination vetting, while supporting initiatives like the State Justice Institute to aid state courts nationwide.

Influence on Alabama and National Politics

As of the Alabama Supreme Court from 1971 to 1977, Heflin spearheaded the Judicial Article amendment to the state constitution, ratified in 1973, which unified the judicial system, required licensed attorneys as judges, ensured legislative funding, and established professional standards. This reform, the first major revision to Alabama's 1901 Constitution, modernized and professionalized the judiciary, reducing political patronage and improving efficiency, thereby influencing the state's legal and political landscape for decades. In the Senate from 1979 to 1997, Heflin advanced Alabama's interests through assignments on the and Committees, securing support for the state's agricultural sector and industry, including facilities like . Nationally, Heflin's chairmanship of the Senate Ethics Committee from the mid-1980s to the mid-1990s positioned him as the chamber's leading authority on ethical conduct, contributing to investigations such as those related to the Iran-Contra affair and enforcing standards amid scandals. On the Judiciary Committee, he influenced federal judicial appointments by recommending Alabama's first African American federal judges, U. W. Clemon and Myron Thompson, under President Carter, and casting decisive votes against Robert Bork's 1987 nomination and ' 1986 federal judgeship bid due to concerns over impartiality. Heflin sponsored key legislation, including the creation of the U.S. Court of Appeals for the Eleventh Circuit in 1981, the Civil Justice Reform Act to expedite federal court processes, and the Reform Act of 1994, which overhauled consumer bankruptcy procedures. His independent, centrist stance as a Southern facilitated , evident in his alignment with moderate positions, resistance to party-switching pressures, and consideration for high posts across administrations, such as U.S. under and justice under Reagan. This approach moderated partisan divides in the , particularly on judicial and ethical matters, while maintaining support for national defense and civil rights advancements. Heflin received the John Marshall Award for his contributions to justice administration, underscoring his broader impact on legal reform.

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