a. Prior to 1937, Supreme Court activism was generally conservative; after 1937, it became even more so. b. Prior to 1937, Supreme Court activism was generally conservative; after 1937, it became liberal. c. Prior to 1937, Supreme Court activism was generally liberal; after 1937, it became even more so. d. Prior to 1937, Supreme Court activism was generally liberal; after 1937, it became conservative. e. Prior to 1937, Supreme Court activism was generally nonexistent; after 1937, it became slightly more common.