Joan Biskupic has an article about Justice Sandra Day OConnor today entitled, oddly enough, "OConnor Not Confined By Conservatism." Biskupic refers to OConnor throughout as a Conservative--acknowledging at one point that "OConnor is a conservative with an asterisk: a pragmatic jurist who, when she sees fit, will vote with the four liberal justices." This is the sort of silly categorization that leads liberals like Cass Sunstein to protest that there are no liberals on the Supreme Court--a statement that surely makes Ginsburg and Stevens feel like Rodney Dangerfield. This fits with a common trend among academics and the legal press to define judicial ideology to the right. Under this scheme, all the liberals are "moderates," the moderates are conservatives, and the conservatives are epithets. But OConnor cannot run from her voting record. She has for years been at best a moderate, and is increasingly shifting not from conservative to moderate, but rather in cases raising issues such as campaign finance law, sovereign immunity, abortion, and affirmative action, she is shifting from moderate to liberal.