Bork opposed the Civil Rights Act of 1964, saying that the provisions within the Act which prohibited racial discrimination by public accommodations were based on a principle of "unsurpassed ugliness". Bork opposed the 1965 Supreme Court ruling in "Griswold v. Connecticut," which struck down a Connecticut law that prohibited the use of contraceptives for married couples. Bork said the decision was "utterly specious," "unprincipled" and "intellectually empty." Bork held that the Constitution only protected speech that was "explicitly political", and that there were no free speech protections for "scientific, literary or that variety of expression we call obscene or pornographic." However, in 1988, an analysis published in "The Western Political Quarterly" of "amicus curiae" briefs filed by U.S. Solicitors General during the Warren and Burger Courts found that during Bork's tenure in the position during the Nixon and Ford Administrations (1973-77), Bork took liberal positions in the aggregate as often as Thurgood Marshall did during the Johnson Administration (1965-67) and more often than Wade H. McCree did during the Carter Administration (1977-81), in part because Bork filed briefs in favor of the litigates in civil rights cases 75 percent of the time (contradicting a previous review of his civil rights record published in 1983).