Alexander Mordecai Bickel (1924–1974) was an American legal scholar and expert on the United States Constitution. One of the most influential constitutional commentators of the twentieth century, his writings emphasize judicial restraint. Life and career Bickel was born on December 17, 1924, in Bucharest, Romania, to Jewish parents, Solomo and Yetta Bickel. The family immigrated to New York City in 1939. He graduated Phi Beta Kappa from City College of New York in 1947 and summa cum laude from Harvard Law School in 1949. Following law school, Bickel was a law clerk for federal judge Calvert Magruder of the United States Court of Appeals for the First Circuit. In 1950, he went to Europe as a law officer of the US State Department, serving in Frankfurt, Germany, and with the European Defense Community Observer Delegation in Paris. In 1952, he returned to the U.S., and clerked for Justice Felix Frankfurter of the Supreme Court in 1952 and 1953. He prepared a historic memorandum for Frankfurter, urging that Brown v. Board of Education be reargued. In 1956, he became an instructor at Yale Law School, where he taught until his death. He was named Chancellor Kent Professor of Law and Legal History in 1966, and Sterling Professor of Law in 1974. He was a friend and colleague of Charles Black, another influential scholar of constitutional law. A frequent contributor to Commentary, New Republic, and The New York Times, Bickel argued against "prior restraint" of the press by the government as part of the successful representation of The New York Times in the Pentagon Papers case (1971). He also defended President Richard Nixon's order to dismiss special Watergate prosecutor Archibald Cox. Bickel died of cancer on November 8, 1974, at his home in Connecticut, at 49 years of age. Contributions Bickel's most distinctive contribution to constitutional law was to stress what he called "the passive virtues" of judicial decision-making – the refusal to decide cases on substantive grounds if narrower grounds exist to decide the case. Bickel viewed "private ordering" and the voluntary working-out of problems as generally preferable to legalistic solutions. In his books The Supreme Court and the Idea of Progress and The Morality of Consent, Bickel attacked the Warren Court for what he saw as its misuse of history, shoddy reasoning, and sometimes arbitrary results. Bickel thought that the Warren Court's two most important lines of decision, Brown v.