"Speaking with a candor he would soon be unable to afford, Mr. Obama directed his fire across the entire political spectrum. He denounced a broken status quo in which cynical Republicans outmaneuvered feckless Democrats in a racialized culture war, leaving most Americans trapped in a system that gave them no real control over their lives. Although his sympathies were clearly with the left, Mr. Obama chided liberals for making do with a “rudderless pragmatism,” and he flayed activists — with the civil rights establishment as his chief example — for asking the judiciary to hand out victories they couldn’t win at the polls. Progressives talked a good game about democracy, but they didn’t really seem to believe in it."
This isn't calling the civil rights movement too radical -- it's criticizing the strategy of relying on courts to grant rights instead of building a political coalition and obtaining rights legislatively. That's a fair criticism.
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The criticism isn't that winning court cases has never done anything, and it's not that it's inappropriate in all circumstances. It's that we may be putting too many eggs in the impact litigation basket, the window when courts were even decently open to this stuff has closed and was an historical aberration, and even big legal wins badly need to be consolidated with legislative action (see Roe v. Wade, see schools remaining segregated long after the courts forbade that).
It can do plenty of good, but it's also a huge resource suck that in many ways overpromises and undelivers.