Counsel to Governor Bush As counsel to Governor Bush, Gonzales helped advise Bush in connection with jury duty when he was called in a 1996 Travis County drunk driving case. The case led to controversy during Bush's 2000 presidential campaign because Bush's answers to the potential juror questionnaire did not disclose Bush's own 1976 misdemeanor drunk driving conviction. Gonzales made no formal request for Bush to be excused from jury duty but raised a possible conflict of interest because as the Governor, Bush might be called upon to pardon the accused party. Gonzales's work in this case has been described as "canny lawyering". As Governor Bush's counsel in Texas, Gonzales also reviewed all clemency requests. A 2003 article in The Atlantic Monthly asserted that Gonzales gave insufficient counsel, and failed to second-guess convictions and failed appeals. Gonzales's deputy general counsel from 1995 to 1999, Pete Wassdorf, in turn sought to defend Gonzales from what he characterized as an inaccurate and incomplete picture of the clemency process under Bush. Under Section II, Article 4 of the Texas Constitution, the Governor cannot grant a pardon or commute a death sentence except with a majority vote recommendation of the Texas Board of Pardons and Paroles, so Bush was constrained in granting clemency even if he had wanted to do so in a case. The fact remains that only one death sentence was overturned by Governor Bush, and the state of Texas executed more prisoners during Gonzales's term than any other state. White House Counsel As White House counsel, and later as attorney general, Gonzales served president George W. Bush through a period of escalating controversy over the legality of U.S. policies in the fight against terrorism. Gonzales approved the legal framework for the administration's anti-terrorism efforts and was a reliable advocate for White House policy. He supported positions that enlarged the power of the executive and diminished protections for interrogation subjects. These rulings were vocally challenged by many scholars and human-rights advocates and were partly overturned by the courts. He resigned following sharp criticism of his handling of the firing of nine U.S. attorneys and subsequent testimony during congressional hearings. Support for use of torture Gonzalez was a supporter of the Bush administration's policy of torture of detainees, internally referred to as "Enhanced interrogation techniques". In January 2002, Gonzales authored a memo that explored whether the Geneva Convention section III on the Treatment