many U.S. states until 1943 when the court overruled its previous decision in the case of West Virginia State Board of Education v. Barnette. A U.S. law magazine noted how Jehovah's Witnesses had helped shape the course of constitutional law, remarking: "Through almost constant litigation this organization had made possible an ever-increasing list of precedents concerning the application of the 14th amendment to freedom of speech and religion". In 1936, Rutherford rejected the belief that Jesus had been executed on a Roman cross, in favor of an upright stake or "tree." Character and attitudes Biographers describe Rutherford as tall and solidly built with a senatorial demeanor, and a strong booming voice that helped make him a powerful orator. In 1917, The New York Times stated that Rutherford "has a reputation as an eloquent, forceful speaker". Watch Tower Society literature states that his personality contrasted strongly with that of his predecessor. One Watchtower history book says that while Russell was kind, warm and tactful, Rutherford "was warm and generous toward his associates but he was also a brusque and direct type of person, and his legal background and experiences in early life gave him a directness in his approach to problems in dealing with his brothers that caused some to take offense." Another Watch Tower Society account says he did not hide his feelings, adding, "His bluntness, even when spoken in kindness, was sometimes misunderstood." Fellow Watch Tower Society director A. H. Macmillan says Rutherford "spoke as simply and directly to the people as he knew how, and he was an extremely forthright man. He was thoroughly convinced that what he had to say was the truth and that it was a matter of life and death." Macmillan added, "He would never tolerate anything that would be contrary to what he clearly understood the Bible to teach. He was so strict about that, he would permit nothing that would seem to show a compromise when it came to an issue of the truth." Author Tony Wills describes him as charitable and generous, and says his sympathy for the poor and oppressed was exceeded only by his hatred for the rich, the oppressors. Wills also notes that he was a dynamic, impatient extrovert. Other authors also address Rutherford's abrasiveness: James Penton describes him as blunt and moody with an explosive temper, with "a streak of self-righteousness which caused him to regard anyone