Rehnquist’s vote was contentious because many Democratic senators believed he was very conservative and would tilt the Court too far to the right. Rehnquist was the most conservative member of the Burger Court. His pattern of filing lone dissents earned him the nickname “the Lone Ranger.” Much of the opposition came from allegations surfacing, or more accurately resurfacing, concerning Rehnquist’s efforts in Phoenix, Arizona, in which he argued against a public accommodations law. There were also unproven allegations that Rehnquist attempted to prevent blacks from voting in a local election. Also, a memo Rehnquist authored when he was a law clerk for Supreme Court Justice Robert H. Jackson in the 1952–53 term on the Brown v. Board of Education school desegregation case raised concerns. In the memo, Rehnquist wrote that the separate but equal doctrine should be upheld. During the Senate confirmation hearings, Rehnquist said that the memo reflected Justice Jackson’s views, not his own. Many historians and legal scholars have questioned that assertion.