judicial review. However, an autumn 1935 Gallup Poll had returned a majority disapproval of attempts to limit the Supreme Court's power to declare acts unconstitutional. For the time being, Roosevelt stepped back to watch and wait. Other alternatives were also sought: Roosevelt inquired about the rate at which the Supreme Court denied certiorari, hoping to attack the Court for the small number of cases it heard annually. He also asked about the case of Ex parte McCardle, which limited the appellate jurisdiction of the Supreme Court, wondering if Congress could strip the Court's power to adjudicate constitutional questions. The span of possible options even included constitutional amendments; however, Roosevelt soured to this idea, citing the requirement of three-fourths of state legislatures needed to ratify, and that an opposition wealthy enough could too easily defeat an amendment. Further, Roosevelt deemed the amendment process in itself too slow when time was a scarce commodity. Unexpected answer Attorney General Cummings received novel advice from Princeton University professor Edward S. Corwin in a letter of December 16, 1936. Corwin had relayed an idea from Harvard University professor Arthur N. Holcombe, suggesting that Cummings tie the size of the Supreme Court's bench to the age of the justices since the popular view of the Court was critical of their age. However, another related idea fortuitously presented itself to Cummings as he and his assistant Carl McFarland were finishing their collaborative history of the Justice Department, Federal justice: chapters in the history of justice and the Federal executive. An opinion written by Associate Justice McReynolds—one of Cumming's predecessors as Attorney General, under Woodrow Wilson—had made a proposal in 1914 which was highly relevant to Roosevelt's current Supreme Court troubles: The content of McReynolds's proposal and the bill later submitted by Roosevelt were so similar to each other that it is thought the most probable source of the idea. Roosevelt and Cummings also relished the opportunity to hoist McReynolds by his own petard. McReynolds, having been born in 1862, had been in his early fifties when he wrote his 1914 proposal, but was well over seventy when Roosevelt's plan was set forth. Reform legislation Contents The provisions of the bill adhered to four central principles: allowing the President to appoint one new, younger judge for each federal judge with 10 years service who did not retire or resign within six months after reaching the age of 70