If the young Merrick Garland had not edited a law review article written by the late U.S. Supreme Court Justice William Brennan Jr. in 1977, he might not have clerked for Brennan and might have pursued a different path than the one that led him to be an appellate judge and Supreme Court nominee.

“Editing your article was enjoyable and exciting, and I would look forward to the prospect of clerking for an even more rewarding experience,” Garland wrote in a May 1977 application letter to Brennan, the liberal justice who died in 1997. The article was on the subject of state constitutions and the protection of individual rights. Garland, then at Harvard Law School, was articles editor for the law review.

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