The phrase originally derives from the title of a 1927 book of that name by Professor Howard Lee McBain, and early efforts at developing the concept in its modern form have been credited to figures like Oliver Wendell Holmes Jr., Louis D. Brandeis, and Woodrow Wilson. The earliest mentions of the Constitution as "living, l" particularly in the context of a new way of interpreting it, comes from Woodrow Wilson's book "Constitutional Government in the United States" in which he wrote: