As for the legacy of the Warren Court, Chief Justice Burger, who succeeded Earl Warren in 1969, proved to be quite ineffective at consolidating conservative control over the Court, so the Warren Court legacy continued in many respects until about 1986, when William Rehnquist became chief justice and took firmer control of the agenda. Even the more conservative Rehnquist Court refrained from expressly overturning major Warren Court cases such as "Miranda", "Gideon", "Brown v. Board of Education", and "Reynolds v. Sims". On occasion, the Rehnquist Court even expanded Warren Court precedents—such as in "Bush v. Gore", where the Rehnquist Court applied the principles of 1960s voting rights cases to invalidate Florida's recount in the 2000 United States presidential election.