Hayes appointed two associate justices to the Supreme Court. The first Supreme Court vacancy arose after David Davis resigned during the election controversy of 1876. On taking office, Hayes filled the vacancy caused by Davis's resignation by appointing John Marshall Harlan, a close ally of Benjamin Bristow. Hayes submitted the nomination in October 1877, but the nomination 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 thirty-four years, in which he voted (usually in the minority) for an aggressive enforcement of 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.