We've known this for more than two decades -- and it's been an issue ever since the court started thinking it was its duty to find penumbras in the constitution -- the American Bar Association is biased against conservative judicial nominees.

The findings:
• Nominees appointed by Democratic presidents are more likely to receive higher ABA ratings than nominees appointed by Republican presidents.
• The more conservative the nominee, the less likely he or she will receive a high ABA rating.
• White nominees are more likely to get higher ratings than minority nominees.
• Nominees with judicial experience receive higher ratings than those without judicial experience.
• Nominees who were previously congressional staff members were more likely to receive lower ratings, but those who served as executive branch attorneys were more likely to receive higher ratings.

This comes just a day after news that the Obama administration has restored the ABA's role in pre-vetting judicial nominees. This should come as little surprise -- because the ABA can be counted on to be fair to Obama's nominees.

As for Obama's first "well qualified" nominee -- just don't call him a moderate.