decision known as Fortson v. Morris, the high court struck down the Bell-Tuttle legal reasoning and directed the legislature to choose between Maddox and Callaway. Two liberal justices, William O. Douglas and Abe Fortas had argued against legislative selection of the governor, but the court majority, led this time by Hugo Black, took the strict constructionist line and cleared the path for Maddox's ultimate election. Attorney General service Bell briefly returned to private practice in Atlanta in 1976. President Jimmy Carter appointed Bell Attorney General of the United States in 1977, serving until 1979. Indictment of L. Patrick Gray On April 10, 1978, Attorney General Bell announced the indictment of former Acting FBI Director L. Patrick Gray, Mark Felt and former FBI Assistant Director Edward Miller for authorizing break-ins of New York City radical political activists. Bell introduced requirements that any authorized illegal activities must be made in writing. Five Department of Justices attorneys resigned over the alleged reluctance of the Attorney Bell to pursue others in the department for illegal activities related to domestic spying. Later career Bell returned to private practice in Atlanta from 1979 until his death in 2009. In September 2004, Bell was appointed the Chief Judge of the United States Court of Military Commission Review. Bell was replaced by Judge Frank J. Williams in July 2007, when the first two cases were appealed to the Court, due to ill health. Death Griffin Bell died on January 5, 2009, in Atlanta. According to the Associated Press, Bell was being treated for complications from pancreatic cancer and had been suffering from long-term kidney disease. Governor Sonny Perdue ordered the flag of the United States flown at half-staff in the state of Georgia on January 7, 2009, the day of Bell's funeral. He is buried in Americus' Oak Grove Cemetery, Section N3-South, where his tombstone bears the inscription "Citizen Soldier, Trial Lawyer, Federal Appellate Judge, Attorney General of the United States." Legacy Bell had a long-standing relationship with the Georgia Historical Society (GHS). He was a member of the institution for over half a century and from 1996 until his death served as Honorary Chairman of its Advisory Board. In 2008, Bell donated his papers to GHS, where they are available for research. See the finding aid for the Griffin B. Bell papers at the Georgia Historical Society. Honors and awards In December 2008, Bell received an honorary