"scathing dissent" argued against the court wading into so-called political questions. Lack of accountability The ethics rules guiding the court's members are set and enforced by the justices, meaning the members of the court have no external checks on their behavior other than the impeachment of a justice by Congress. Lower courts, by contrast, discipline according to the 1973 Code of Conduct for U.S. judges which is enforced by the Judicial Conduct and Disability Act of 1980. The lack of external enforcement of ethics or other conduct violations makes the Supreme Court an extreme outlier in modern organizational best-practices. Lifetime tenure Critic Larry Sabato wrote: "The insularity of lifetime tenure, combined with the appointments of relatively young attorneys who give long service on the bench, produces senior judges representing the views of past generations better than views of the current day." Sanford Levinson has been critical of justices who stayed in office despite medical deterioration based on longevity. James MacGregor Burns stated lifelong tenure has "produced a critical time lag, with the Supreme Court institutionally almost always behind the times." Proposals to solve these problems include term limits for justices, as proposed by Levinson and Sabato and a mandatory retirement age proposed by Richard Epstein, among others. However, others suggest lifetime tenure brings substantial benefits, such as impartiality and freedom from political pressure. Alexander Hamilton in Federalist 78 wrote "nothing can contribute so much to its firmness and independence as permanency in office." Not choosing enough cases to review Senator Arlen Specter said the court should "decide more cases"; on the other hand, although Justice Scalia acknowledged in a 2009 interview that the number of cases that the court heard then was smaller than when he first joined the Supreme Court, he also stated that he had not changed his standards for deciding whether to review a case, nor did he believe his colleagues had changed their standards. He attributed the high volume of cases in the late 1980s, at least in part, to an earlier flurry of new federal legislation that was making its way through the courts. Power excess This criticism is related to complaints about judicial activism. George Will wrote that the court has an "increasingly central role in American governance." It was criticized for intervening in bankruptcy proceedings regarding ailing carmaker Chrysler Corporation in 2009. A reporter wrote that "Justice Ruth Bader Ginsburg's intervention in the