by Franklin D. Roosevelt or Truman, and all were committed New Deal liberals. They disagreed about the role that the courts should play in achieving liberal goals. The Court was split between two warring factions. Felix Frankfurter and Robert H. Jackson led one faction, which insisted upon judicial self-restraint and insisted courts should defer to the policymaking prerogatives of the White House and Congress. Hugo Black and William O. Douglas led the opposing faction that agreed the court should defer to Congress in matters of economic policy, but felt the judicial agenda had been transformed from questions of property rights to those of individual liberties, and in this area courts should play a more central role. Warren's belief that the judiciary must seek to do justice, placed him with the latter group, although he did not have a solid majority until after Frankfurter's retirement in 1962. Decisions Warren was a more liberal justice than anyone had anticipated. Warren was able to craft a long series of landmark decisions because he built a winning coalition. When Frankfurter retired in 1962 and President John F. Kennedy named labor union lawyer Arthur Goldberg to replace him, Warren finally had the fifth vote for his liberal majority. William J. Brennan, Jr., a liberal Democrat appointed by Eisenhower in 1956, was the intellectual leader of the faction that included Black and Douglas. Brennan complemented Warren's political skills with the strong legal skills Warren lacked. Warren and Brennan met before the regular conferences to plan out their strategy. Brown v. Board of Education (1954) Brown v. Board of Education banned the segregation of public schools. The very first case put Warren's leadership skills to an extraordinary test. The Legal Defense Fund of the NAACP (a small legal group formed for tax reasons from the much better known NAACP) had been waging a systematic legal fight against the "separate but equal" doctrine enunciated in Plessy v. Ferguson (1896) and finally had challenged Plessy in a series of five related cases, which had been argued before the Court in the spring of 1953. However the justices had been unable to decide the issue and asked to rehear the case in fall 1953, with special attention to whether the Fourteenth Amendment's Equal Protection Clause prohibited the operation of separate public schools for whites and blacks. While all but one justice personally rejected segregation, the self-restraint faction questioned whether the