Judicial biography, writes Dean Larry Kramer, is a difficult genre. The work of judges is not often exciting and cases that a judge decides tend to make up the substance of a judicial life. But, Kramer notes, reading about lawsuits can be less than stimulating.

In reviewing Justice Brennan: Liberal Champion, Kramer finds the authors “were unable to surmount the inherent limitations of the genre.” Kramer notes that the authors faced some serious constraints: Justice Brennan’s life was not particularly interesting before he went on the bench, he was involved in almost nothing off the bench, and he was extremely reserved in and about his personal life. Although Brennan was a friendly, gregarious, and likeable person, Kramer thinks that these qualities themselves made up a form of reserve.