He'd represented a grade-school autistic student who sued the Manhattan Beach Unified School District and the California Department of Education for failing to provide him with an appropriate education, including extra reading instruction.

FORBES: A Costly Education

James Blythe, now a student at Oxford, was given a D grade for coursework in his history A-level last year - in contrast to much higher marks for other parts of the exam.

BBC: A-level marking 'grossly unjust'

Or, on a school grading system, a "D" --- the same grade as in 2007.

CNN: King: Waterman finds Chesapeake Bay 'dying daily'

Again, with the caution that exams taken in isolation cannot be easily assessed, he says that a D grade is much too low - and he suggests that a B might be more appropriate.

BBC: A-level marking 'grossly unjust'