did not constitute a compelling interest. Virginia does have a governmental interest in regulating the practice of law, Brennan said, because litigation can be malicious: It can abuse the legal system for personal gain, it can be used to oppress others, and lay people can urge the use of the legal system for their own personal financial gain. But "the exercise ... of First Amendment rights to enforce constitutional rights through litigation, as a matter of law, cannot be deemed malicious." Yet First Amendment litigation is exactly the sort of activity the Virginia laws sought to bar. Furthermore, Virginia could not show at trial any substantive evil flowing from the NAACP's activities. The judgment of the Virginia Supreme Court of Appeals was reversed. Douglas' concurrence Associate Justice Douglas concurred in the Court's ruling. He addressed the dissent by pointing out that not only the laws' legislative history, but both the district court and the Virginia Supreme Court of Appeals clearly found that the legislature passed them to discriminate against the NAACP and to circumvent the U.S. Supreme Court's rulings. "[T]hey make clear the purpose of the present law — ... to evade our prior decisions... The fact that the contrivance used is subtle and indirect is not material to the question." White's concurrence and dissent Associate Justice Byron White concurred in the Court's judgment, but dissented from its reasoning. White thought that the five Virginia legal business laws unconstitutionally infringed on freedom of speech and the constitutionally protected lawful exercise of the court system to ensure the full exercise of those rights. A more narrowly drawn statute, White felt, may have passed constitutional scrutiny, but the majority's decision appeared unable to admit such an outcome. White would not have discussed the maliciousness of the NAACP's activities, as that issue was not properly before the Court. Harlan's dissent Associate Justice John Marshall Harlan II, who had written the majority opinion in Harrison v. NAACP, now wrote the dissent, joined only by Associate Justices Tom C. Clark and Potter Stewart. Harlan argued that the record before the Court clearly showed that the lawyers working for the NAACP were members of the organization's legal staff, that NAACP policy and officers controlled the lawyers' actions, and that the NAACP did not merely represent clients who came to it but instead actively sought out very specific types of clients to advance its policy agenda. Thus