In 1922 Charles Garland, a student at Harvard College, donated $800,000 to establish the American Fund for Public Service, a foundation dedicated to radical social reform. The fund, generally known as the Garland Fund, awarded a $100,000 grant to the NAACP for the employment of a special counsel to study the legal status of African Americans and plan a legal campaign. The NAACP hired Nathan Margold, a former assistant U.S. attorney for the Southern District of New York, on the endorsement of attorneys Felix Frankfurter and Charles Houston. Margold focused his report on an assessment of discrimination in public schools. He advised the NAACP to “boldly challenge the constitutional validity” of underfunded black schools as a violation of the equal protection clause of the Fourteenth Amendment.