followers...he was a dull man and a dull judge." Conservatives attacked the Warren Court's rulings as inappropriate and have called for courts to be deferential to the elected political branches. In his 1977 book Government by Judiciary, originalist and legal scholar Raoul Berger accuses the Warren Court of overstepping its authority by interpreting the 14th Amendment in a way contrary to the original intent of its draftsmen and framers in order to achieve results that it found desirable as a matter of public policy. Overall, law professor Justin Driver divides interpretations of the Warren Court into three main groups: conservatives such as Robert Bork who attack the Court as "a legislator of policy...that was not theirs to make", liberals such as Morton Horwitz who strongly approve of the Court, and liberals such as Cass Sunstein who largely approve of the Court's overall legacy but believe that it went too far in making policy in some cases. Driver offers a fourth view, arguing that the Warren Court took overly conservative stances in such cases as Powell v. Texas and Hoyt v. Florida. As for the legacy of the Warren Court, Chief Justice Burger, who succeeded Earl Warren in 1969, proved to be quite ineffective at consolidating conservative control over the Court, so the Warren Court legacy continued in many respects until about 1986, when William Rehnquist became chief justice and took firmer control of the agenda. Even the more conservative Rehnquist Court refrained from expressly overturning major Warren Court cases such as Miranda, Gideon, Brown v. Board of Education, and Reynolds v. Sims. On occasion, the Rehnquist Court expanded Warren Court precedents, such as in Bush v. Gore, where the Rehnquist Court applied the principles of 1960s voting rights cases to invalidate Florida's recount in the 2000 U.S. presidential election. Memorials and honors Earl Warren was awarded the Presidential Medal of Freedom posthumously in 1981. He was also honored by the United States Postal Service with a 29¢ Great Americans series postage stamp. In December 2007, Warren was inducted into the California Hall of Fame. An extensive collection of Warren's papers, including case files from his Supreme Court service, is located at the Manuscript Division of the Library of Congress in Washington, D.C. Most of the collection is open for research. On the campus of the University of California, Berkeley, Warren's alma mater, "Earl Warren Hall" is named after him. In