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When legendary appeals judge Learned Hand did not like how the U.S. Supreme Court disposed of one of his cases in 1954, he protested privately to Justice Felix Frankfurter. “I felt…a sense of professional incapacity,” Hand confessed in a letter, according to Gerald Gunther’s 2004 biography of Hand. “It does serve as a warning…that what may seem to oneself [entirely clear] may seem to others plain tosh” or nonsense.
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