In 1976 he decided to refer a series of tough state security Bills to the Supreme Court to test their constitutionality. This worried and angered members of the Fine Gael-Labour national coalition government. Ó Dálaigh then announced that he would sign the bill at midnight of the 15th of October, which he made public. There was a historical precedent for the referral of this bill. Dubhghlas de hÍde referred the Offences Against the State (Amendment) Act of 1939 to the Supreme Court. Jim Duffy claims that, as a result of this, the PIRA arranged an attack in Mountmellick which resulted in the killing of Garda Clerkin. Others would dispute that the PIRA would have held the President's opinion in such high regard as their members at the time did not recognise the State of which Ó Dálaigh was then the Head.