It was not much of a surprise that the Supreme Court denied review this morning in Ebbers v. United States, the appeal of former WorldCom CEO Bernard Ebbers against his criminal conviction on securities fraud charges. But there was an interesting twist: Chief Justice John Roberts, Jr. announced he "took no part" in the Court's action. No obvious stock ownership conflicts, but here might be the answer: Roberts was still at his old law firm Hogan & Hartson in late 2002 and early 2003 when the firm's New York office began representing Ebbers in separate civil actions brought against him by WorldCom employees. There's no indication Roberts worked on the cases, but that might have been enough of a connection for Roberts to recuse now. Nearly four years after he left Hogan for the D.C. Circuit and then the Supreme Court, these conflicts don't crop up often anymore for Roberts, but for long-running firm clients like Ebbers, they may continue for awhile longer. See Legal Times' Recusal Report for information on other recusal decisions by Roberts and other justices earlier this term.