Justice Horace Gray instituted the practice of law clerks in 1882 when he joined the Court. When he was a member of the Supreme Judicial Court of Massachusetts, Gray had started the practice there as well, hiring future Supreme Court justice Louis Brandeis. Gray paid for the clerk out of his own pocket. The practice became formalized when Congress passed a 1922 law that allowed each justice to hire one law clerk for a salary of $3,600.