Bell’s article was written in the sober, even painstaking, tone typical of contributions to American law reviews, with lengthy citations to relevant cases often taking up the bulk of each page. But anybody who read it must have recognized that his conclusion was a political bombshell. Drawing on a line of argument that (as Bell himself acknowledged) had originally been advanced by racist opponents of desegregation, he warned that civil rights lawyers were trying to “serve two masters” at the same time.
