Courts should take to heart former Kramer Levin partner Judge Marvin Frankel's oft-stated views on the adversary system, a recent article in the New York Law Journal said. Judge Frankel, a respected trial judge, author and litigator passed away on March 3.

Judge Frankel had long argued that trial judges serve best as relatively passive moderators. The August 29 article, "Two Court of Appeals Rulings Redefine the Role of the Trial Judge," which reviews two recent and noteworthy New York Court of Appeals decisions, said that courts should heed Frankel's words, lest they risk providing more confusion than guidance with their sporadic interference.