In Sunday’s New York Times, Linda Greenhouse refers to liberal legal scholars’ 
attempts to promote a “Shadow Constitution.”

http://www.nytimes.com/2003/06/22/weekinreview/22GREE.html

Greenhouse has used this term before, in a 1995 post-Lopez NYT piece contrasting 
liberals' shadow constitution with conservatives’ “constitution-in-exile.”

Does anyone know where the phrase “Shadow Constitution” originated?

(I understand the metaphor of the shadow cabinet, and a Lexis-Nexis search shows that 
Mark Graber (2002) and Jack Balkin (1997) have used the phrase when criticizing the 
tendency on the part of some progressive scholars to focus on elaborating and 
defending the unfashionable constitutional doctrines that make up a shadow 
constitution. Neither, however, explains the origins of the phrase.)

Because Greenhouse referred to this phrase before Balkin did, I am also left to wonder 
who were the scholars that fell within this tradition.  Scholars whose views often 
fell quite far to the left of the Warren Court, such as Charles Black, Charles Reich, 
or Arthur Miller?  Or, is this term referring to post-Warren Court era scholars?

Any help off-list would be very much appreciated.

Lynda Dodd

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