In 1982, a 72-year-old senior judge of the United States Court of Appeals for the District of Columbia, Judge David L. Bazelon, resigned from the governing panel of the ACA with a 21-page statement of criticism. Bazelon had three years remaining on his five-year term. He described its lack of transparency and accountability, its apparent willingness to bend to political influence, and its dual role as a trade group and accreditor. Bazelon pointed out the apparent conflict of interest, writing, "How can the commission in good conscience represent itself as 'independent' and 'unbiased' while being financially dependent on the objects of its scrutiny?"