June 6, 1968, and received his commission on June 7, 1968. Notable cases Pratt presided over a number of high-profile cases during his time on the bench, including the trial of G. Gordon Liddy in connection with the Watergate scandal. In 1974, Pratt oversaw the bench trial of Libby, finding him guilty of two counts of contempt of Congress. Pratt also presided over Hoffa v. Saxbe, a case in which former Teamsters leader James R. Hoffa unsuccessfully made a constitutional challenge to the condition of his 1971 presidential pardon barring him from engaging in "direct or indirect management of any labor union" until March 1980. Pratt ruled in 1974 that the condition of the pardon was valid because (1) it had a direct relationship to the public interest and (2) it did not "unreasonably infringe" on Hoffa's constitutional freedoms. Pratt also issued rulings on important civil rights issues. He ordered the restoration of the Defense Department security clearances of two homosexuals in 1971, holding that "government security evaluators cannot subject homosexuals to 'probing personal questions' about their sex lives or withhold security clearances for refusal to answer such questions." Pratt also presided over another case, Adams v. Richardson, brought by the NAACP Legal Defense and Educational Fund. The NAACP sought to compel the United States Department of Health, Education and Welfare (HEW) to speed up desegregation in schools. Pratt rejected the HEW's argument that Title VI of the Civil Rights Act of 1964 gave the department the discretion to wait for "voluntary compliance" from the states. Citing Alexander v. Holmes County Board of Education, Pratt ruled that desegregation was to occur "at once" in the 113 school districts, mostly in the South, that had failed to desegregate. Pratt also ordered the withholding of federal funding from school districts that failed to comply. Pratt's decision was largely affirmed by the United States Court of Appeals for the District of Columbia Circuit, although it set a ten-month timeframe for states to create desegregation plans, rather than the four-month timeframe set by Pratt. Pratt also oversaw the long-running Evans case, involving conditions at the District of Columbia's Forest Haven institution in Laurel, Maryland, a home for persons with intellectual and developmental disabilities. Pratt determined that "patients' constitutional rights to adequate care and treatment had been violated" and issued an order setting forth sweeping changes to be made at the facility, including the movement