of circumstantial evidence surrounds Frank Murphy, who was dogged by "rumors of homosexuality ... all his adult life". For more than 40 years, Edward G. Kemp was Frank Murphy's devoted, trusted companion. Like Murphy, Kemp was a lifelong bachelor. From college until Murphy's death, the pair found creative ways to work and live together. [...] When Murphy appeared to have the better future in politics, Kemp stepped into a supportive, secondary role. As well as Murphy's close relationship with Kemp, Murphy's biographer, historian Sidney Fine, found in Murphy's personal papers a letter that "if the words mean what they say, refers to a homosexual encounter some years earlier between Murphy and the writer." However, the letter's veracity cannot be confirmed, and a review of all the evidence led Fine to conclude that he "could not stick his neck out and say [Murphy] was gay". Speculation has also surrounded Benjamin Cardozo, whose celibacy was proposed to suggest repressed homosexuality or asexuality. The fact that he was unmarried and was personally tutored by the writer Horatio Alger (alleged to have had sexual relations with boys) led some of Cardozo's biographers to insinuate that Cardozo was homosexual, but no real evidence exists to corroborate this possibility. Constitutional law scholar Jeffrey Rosen noted in a The New York Times Book Review of Richard Polenberg's book on Cardozo: Polenberg describes Cardozo's lifelong devotion to his older sister Nell, with whom he lived in New York until her death in 1929. When asked why he had never married, Cardozo replied, quietly and sadly, "I never could give Nellie the second place in my life." Polenberg suggests that friends may have stressed Cardozo's devotion to his sister to discourage rumors "that he was sexually dysfunctional, or had an unusually low sexual drive or was homosexual." But he produces no evidence to support any of these possibilities, except to note that friends, in describing Cardozo, used words like "beautiful", "exquisite", "sensitive" or "delicate." Andrew Kaufman, author of Cardozo, a biography published in 2000, notes that "Although one cannot be absolutely certain, it seems highly likely that Cardozo lived a celibate life". Judge Learned Hand is quoted in the book as saying about Cardozo: "He [had] no trace of homosexuality anyway". More recently, when David Souter was nominated to the court, "conservative groups expressed concern to the White House ... that the president's bachelor nominee might conceivably be a