a Maryland state legislator.

Whether Duvall is deserving of the title of "the most insignificant" justice in the history of the U.S. Supreme Court has been the subject of much academic interest, most notably a debate between University of Chicago Law Professors David P. Currie and (now-Judge) Frank H. Easterbrook in 1983. Currie argued that "impartial examination of Duvall's performance reveals to even the uninitiated observer that he achieved an enviable