This chapter details events following Marshall's arrival in Kenya in 1963. It had been three years since Marshall had last been to the country. In early 1960, independence had been a demand. Now it was an inevitability, with ceremonies scheduled for December. Jomo Kenyatta, still in detention in 1960, his influence feared by the British and Americans, had instead emerged as a moderating voice after his release in 1961. He had carried the Kenya African National Union (KANU) to power, and was now prime minister during the colony's short period of self-rule. As for Marshall, bruising Court of Appeals confirmation hearings were now behind him. The civil rights lawyer had settled into life on the court.
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