While the problem has been around for some time, the current manifestation can be traced to the Powell memo of 1971. https://en.wikipedia.org/wiki/Lewis_F._Pow

While the problem has been around for some time, the current manifestation can be traced to the Powell memo of 1971. https://en.wikipedia.org/wiki/Lewis_F._Powell_Jr.#Powell_Memorandum,_1971 https://en.wikipedia.org/wiki/Lewis_F._Powell_Jr.#Powell_Mem...