to cover issues of public concern without undue exposure to suits for libel. The reasoning of the Chapadeau decision was influential with courts throughout the United States. Also known for the remark, "A marriage license should not be viewed as a license for a husband to forcibly rape his wife with impunity" (in People v. Liberta), Wachtler was a key figure in making spousal rape a criminal offense. Wachtler wrote the majority opinion in a 1988 right to die case interpreting the statute's requirement of "clear and convincing evidence" that a person who can no longer communicate would have wanted to die in a particular circumstance. The majority opinion set a stricter standard of "clear and convincing" than the lower courts, and refused to let a patient's family withdraw life support. General statements by a person that he or she would not want to live in such a condition are not acceptable under the decision. The decision was criticized by right-to-die organizations as being too strict and unworkable, and taking decision-making away from family members. Wachtler was criticized for writing the decision while his own 86-year-old mother was recovering from a stroke. His formulation of this higher standard of proof was later adopted by the United States Supreme Court. As Chief Judge, Wachtler served not only as the head of the Court of Appeals, but also as the chief administrator for the state court system. He made significant administrative changes, called for the merit selection of judges, implemented streamlined procedures, reduced opportunities for "judge shopping," and reformed the state's grand jury system. Wachtler also tried to improve women's and minorities' access to justice. He created a New York State Judicial Commission for Minority Concerns, a Workforce Diversity Program, and a New York State Task Force on Gender Bias. Criminal charges and resignation In 1988, Wachtler began an affair with Joy Silverman. At the time, Wachtler was a co-executor of the estate of Alvin Wolosoff, Silverman's stepfather and the uncle of Wachtler's wife. He was also trustee of four trusts stemming from Wolosoff's estate for the benefit of Silverman and her family. The trusts (in aggregate) were reported to be worth US$24 million at the time. According to then-United States Attorney Michael Chertoff, over time, Wachtler received fees of more than US$800,000 for his work as executor and trustee of the entire estate. After Silverman ended the affair in September 1991,