United States Supreme Court (by Jeff Kubina, via Wikimedia Commons) In August 1971, shortly before accepting Richard Nixon's nomination to the Supreme Court, Lewis Powell wrote a confidential memorandum to the US Chamber of Commerce. In the document, Powell argued that the American system of free enterprise was under attack by leftist groups, and he envisioned a strategy to fight back against those forces that were, in his view, anti-business. "[B]usinessmen have not been trained or equipped to conduct guerrilla warfare with those who propagandize against the system, seeking insidiously and constantly to sabotage it," Powell wrote. He praised business executives for having performed "very well indeed" the role "to manage, to produce, to sell, to create jobs, to make profits, to improve the standard of living, to be community leaders, to serve on charitable and educational boards, and generally to be good citizens." However, he argued th...