By the mid-20th century, it had become apparent that the United States District Court for the District of Columbia had long outgrown its "completely outmoded and cramped" accommodations. A new courthouse was desperately needed, argued F. Regis Noel in a January 1941 article in the Journal of the Bar Association of the District of Columbia. Noel, a member of the D.C. Bar and a law professor at Georgetown and Catholic University, further contended that the legal community would be "outraged" if the new facility were not located in Judiciary Square, consistent with Pierre L'Enfant's original plan for the federal city. Eventually, of course, the current E. Barrett Prettyman Federal Courthouse opened in Judiciary Square in November 1952.

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