Chrysler bankruptcy" left open the "possibility of further judicial review" but argued overall that the intervention was a proper use of Supreme Court power to check the executive branch. Warren E. Burger, before becoming Chief Justice, argued that since the Supreme Court has such "unreviewable power", it is likely to "self-indulge itself", and unlikely to "engage in dispassionate analysis." Larry Sabato wrote "excessive authority has accrued to the federal courts, especially the Supreme Court." The 2021–2022 term of the court was the first full term following the appointment of three judges by Republican president Donald Trump — Neil Gorsuch, Brett Kavanaugh, and Amy Coney Barrett — which created a six-strong conservative majority on the court. Subsequently, at the end of the term, the court issued a number of decisions that favored this conservative majority while significantly changing the landscape with respect to rights. These included Dobbs v. Jackson Women's Health Organization which overturned Roe v. Wade and Planned Parenthood v. Casey in recognizing abortion is not a constitutional right, New York State Rifle & Pistol Association, Inc. v. Bruen which made public possession of guns a protected right under the Second Amendment, Carson v. Makin and Kennedy v. Bremerton School District which both weakened the Establishment Clause separating church and state, and West Virginia v. EPA which weakened the power of executive branch agencies to interpret their congressional mandate. Several observers considered this a shift of government power into the Supreme Court, and a "judicial coup" by some members of Congress including Representative Alexandria Ocasio-Cortez, urging action to reform the Supreme Court. Secretive proceedings The court has been criticized for keeping its deliberations hidden from public view. For example, the increasing use of a 'shadow docket' facilitates the court making decisions in secret without hearing oral arguments or giving an explanation regarding its ruling. According to a review of Jeffrey Toobin's 2007 book The Nine: Inside the Secret World of the Supreme Court; "Its inner workings are difficult for reporters to cover, like a closed 'cartel', only revealing itself through 'public events and printed releases, with nothing about its inner workings.'" The reviewer writes: "few (reporters) dig deeply into court affairs. It all works very neatly; the only ones hurt are the American people, who know little about nine individuals with enormous power over their lives." A Fairleigh Dickinson University poll conducted in 2010 found that 61% of American voters