He became known for his domineering personality and the 'Johnson treatment', his aggressive coercion of powerful politicians to advance legislation. Along with Speaker of the U.S. House of Representatives Sam Rayburn, Senate Majority Whip Earle Clements, and House Majority Whip Carl Albert, Johnson did not sign the 1956 Southern Manifesto drafted by Dixie South Democrats in the 84th U.S. Congress, despite all representing states where racial segregation of public schools had been legally required prior to the 1954 Brown v. Board of Education U.S. Supreme Court case. After he left office in January 1969, Johnson returned to his Texas ranch, where he died of a heart attack at age 64, on January 22, 1973. Stevenson went to court, eventually taking his case before the US Supreme Court, but with timely help from his friend and future US Supreme Court Justice Abe Fortas, Johnson prevailed on the basis that jurisdiction over naming a nominee rested with the party, not the federal government.