One of the first times the phrase "living Constitution" was expressly used inside the court room was by the [[liberal]] four-Justice dissent in ''[[Rummel v. Estelle]]''<ref>[https://supreme.justia.com/cases/federal/us/445/263/case.html Rummel v. Estelle, 445 U.S. 263 (1980)]</ref>. It has been embraced by the left side of the Court in numerous rulings since. | One of the first times the phrase "living Constitution" was expressly used inside the court room was by the [[liberal]] four-Justice dissent in ''[[Rummel v. Estelle]]''<ref>[https://supreme.justia.com/cases/federal/us/445/263/case.html Rummel v. Estelle, 445 U.S. 263 (1980)]</ref>. It has been embraced by the left side of the Court in numerous rulings since. |