Ross E. Davies has issued a correction to his article, “The Judicial and Ancient Game: James Wilson, John Marshall Harlan, and the Beginnings of Golf at the Supreme Court,” published in the July 2010 (vol. 35, no. 2) issue of the Journal. Specifically, he takes issue with this sentence on page 129: “I have found no evidence that anyone else who was on the Court when Harlan returned from Murray Bay with his clubs for the 1897 Term had ever played the game—not Stephen J. Field (1863–1897), Horace Gray (1882–1902), Melville W. Fuller (1888–1910), David J. Brewer (1890–1910), Henry B. Brown (1891–1906), George Shiras, Jr. (1892–1903), Edward D. White (1894–1921), or Rufus W. Peckham (1896–1909). Moreover, of Harlan's eight 1897 colleagues, only a couple—Chief Justice Fuller and Justice Brewer—would eventually pick it up.”

Ross writes: I was wrong. Justice Gray did take up golf. He said so in an August 19, 1900, letter to Chief Justice Fuller. Writing from his house in Nahant, Massachusetts, Gray reported that he was “[r]eading and thinking and making notes about Marshall [Gray was preparing a speech about Chief Justice John Marshall that he would deliver at a bar association event in Richmond, Virginia in February 1901], with healthful interspersing of driving and golfing and otherwise enjoying the healthful open air. …” Horace Gray to Melville Fuller, August 19, 1900, in Box 5, Papers of Melville W. Fuller, Library of Congress, Manuscript Division. Wider and more careful reading would have brought this fact to my attention. Gray's golfing was reported, for example, in the June 1904 issue of the Proceedings of the American Academy of Arts and Sciences: “He loved to be out of doors, went often into the woods fishing and shooting; notwithstanding his great size he rode on horseback until middle life, and later took up the game of golf.” Francis C. Lowell, “Horace Gray,” 39 Proceedings of the American Academy of Arts and Sciences 627, 637 (June 1904).