future Supreme Court Justice Elena Kagan pointed out that the O'Brien court did not appear to be concerned whether the law as enacted or enforced "matched, or even resembled" the asserted government interest of stopping draft resistance protests. Kagan noted that the law prohibiting the destruction of the draft card "interfered" with only one point of view: that of the anti-war protester. She allowed as how a successful challenge to O'Brien might come from focusing on such skewed constraints. Rallies On Armed Forces Day in the United States (Saturday, May 16, 1964), in New York, 12 students at a rally burned their draft cards. At the University of California, Berkeley, on May 5, 1965, amid a protest march of several hundred people carrying a black coffin to the Berkeley draft board, 40 men burned their draft cards. One of them told reporters the act was symbolic—he said "we can get new cards if we apply for them." On May 22, 1965, the Berkeley draft board was visited again, with 19 men burning their cards. President Lyndon B. Johnson was hanged in effigy. In August 1965, Life carried a photograph of a man demonstrating in front of the Armed Forces Induction Center on Whitehall Street in Manhattan, July 30, 1965. Like David J. Miller a few months later, he was a member of the Catholic Worker Movement. He was not arrested. Antiwar activist Abbie Hoffman burned his draft card privately in the spring of 1967. Hoffman's card classified him as 4F—unfit for service—because of bronchial asthma. His act was purely symbolic; he would never be drafted. However, Hoffman supported those registrants who were burning their cards. On April 15, 1967, at Sheep Meadow, Central Park, New York City, some 60 young men including a few students from Cornell University came together to burn their draft cards in a Maxwell House coffee can. Surrounded by their friends who linked arms to protect them, the men began burning their cards. Others rushed in to join them, holding their burning cards up in the air. Watching this were police, FBI men, newsreel cameramen, reporters, photographers and passers-by. Uniformed Green Beret Army reservist Gary Rader walked to the center and burned his draft card. The 23-year-old was arrested by FBI agents several days later at his home in Evanston, Illinois. Time magazine estimated 75 total cards; participant Martin Jezer wrote that there were about 158