As governor of Texas he [Bush] indicated that judicial niceties were not at the top of his concerns. A study by the Chicago Tribune, published in June 2000, showed that he had refused clemency in all 131 death cases that had reached him. (Alberto Gonzales was legal counsel to Governor Bush and provided memoranda on clemency petitions.) Bush explained that the defendants had had "full access to a fair trial." In a third of those cases the lawyer who represented the defendant at trial or on appeal had been or was later disbarred or otherwise sanctioned.