militant bitterness however great. On 2 October 1933, Gürtner was made a member of Hans Frank's Academy for German Law at its inaugural meeting. Also in 1933, Gürtner came into conflict with one of his subordinates in the Justice Ministry, Roland Freisler, over the issues of Rassenschande (literally: "racial disgrace"), or sexual relationship between an "Aryan" and a "non-Aryan", which Freisler wanted immediately criminalized. Gürtner, in a meeting, pointed out many practical difficulties with Freisler's proposal. This did not, however, stop the passage of the Nuremberg Laws two years later, criminalizing Rassenschande. In the weeks following the Night of the Long Knives, a purge of SA officers and conservative critics of the regime that resulted in perhaps hundreds of executions, he demonstrated his loyalty to the Nazi regime by writing a law that added a legal veneer to the purge. Signed into law by both Hitler and Minister of the Interior Wilhelm Frick, the "Law Regarding Measures of State Self-Defense" retroactively legalized the murders committed during the purge. Gürtner even quashed some initial efforts by local prosecutors to take legal action against those who carried out the murders. As a part of bid to retain a role for the judiciary in the repression of enemies of the state and to protect the rechtsstaat, Gürtner opened the first session of the People's Court on 14 July 1934. The People's Court was a special court for trying those accused of being enemies of the state, whose procedures were meant to ensure the conviction of the accused. Starting in 1933, Gürtner found himself uneasily attempting to maintain the rule of law in Germany by bending the rules of the laws to suit Hitler, a process that steadily involved him and the rest of the German judiciary into excusing and justifying terror. In July 1935, Gürtner amended Paragraph 175 of the German penal code to extend its scope and increased the penalties. By the end of 1935, it was already apparent that neither Gürtner nor Frick would be able to impose limitations on the power of the Gestapo, or control the SS camps where thousands of detainees were being held without judicial review. Instead of resigning, Gürtner again stayed on. To mark the fourth anniversary of the Nazi regime on 30 January 1937, Hitler determined to enroll all the remaining non-Nazi ministers in the Nazi Party and to confer personally upon them the Golden