Nearly a century ago, U.S. Spureme Court Justice Louis D. Brandeis praised the tradition of federalism in his dissent in New State Ice v. Liebmann, which popularized the term “laboratory of democracy.” Brandeis underscored that states, using their sovereign power, have the freedom to experiment with new legislation that responds to the evolving needs of their citizens. Decades later, in his dissent in Michigan v. Mosley, Justice William Brennan advanced Brandeis’ thesis by calling on state courts to impose higher standards and afford greater protections to civil liberties under their state constitutions than the U.S. Constitution. He reiterated his call two years later in the Harvard Law Review, urging lawyers and others to look to state constitutions for broader protections of individual rights than the U.S. Supreme Court was then finding the U.S. Constitution to guarantee.