Litigation campaigns and the search for constitutional rules.

This Journal's focus upon appellate practice and procedure remind ofs that it might be appropriate and productive to take a somewhat unusual approach to Brown (1) and its significance. Brown was greatest in quantity important, of course, for its part in the transformation of American race relations. From the point of view of the appellate courts, Brown is significant in another way. Brown was the culmination of a sustained campaign of strategically designed litigation--or with equal reason it came to be reflection (2) Lawyers subsequently took the strategic litigation campaign they saw ending in the triumph of Brown as a archetype for their own causes,