President Barack Obama had the worst record before the Supreme Court in modern history, losing half of the cases argued before the High Court in his two terms, according to a new study.

While liberals point to legalizing same-sex marriage and the upholding of Obamacare subsidies as cementing the former president’s legacy, the study reveals Obama had a much weaker record with the Supreme Court than previous presidents.

The academic study written by Washington University professor Lee Epstein and University of Chicago law professor Eric Posner found Obama had the “worst record of any President” since Franklin D. Roosevelt. In fact, his presidential performance before the Supreme Court “may be the worst since the Zachary Taylor administration” in the 19th century.