Hayes appointed two Associate Justices to the Supreme Court. The first vacancy occurred when David Davis resigned to enter the Senate during the election controversy of 1876. On taking office, Hayes appointed John Marshall Harlan to the seat. A former candidate for governor of Kentucky, Harlan had been Benjamin Bristow's campaign manager at the 1876 Republican convention, and Hayes had earlier considered him for attorney general. Hayes submitted the nomination in October 1877, but it aroused some dissent in the Senate because of Harlan's limited experience in public office. Harlan was nonetheless confirmed and served on the court for 34 years, voting (usually in the minority) for aggressive enforcement of the civil rights laws. In 1880, a second seat became vacant upon the resignation of Justice William Strong. Hayes nominated William Burnham Woods, a carpetbagger Republican circuit court judge from Alabama. Woods served six years on the Court, ultimately proving a disappointment to Hayes as he interpreted the Constitution in a manner more similar to that of Southern Democrats than to Hayes's own preferences.