Lemon, Furman, Roe, and other legal bizarreries caught conservatives off guard in the early '70s. Then the Right organized. Read how it happened in my review in First Principles of Steven M. Teles's The Rise of the Conservative Legal Movement.

Conservatives falling for the same old tricks?....

"Obama's purpose should have been obvious. For the past eight years, the Democrats have made intense and persistent use of the Two Minute Hate technique that George Orwell described in Nineteen Eighty-Four:

The Hate had started. As usual, the face of Emmanuel Goldstein, the Enemy of the People, had flashed on to the screen...The programmes of the Two Minutes Hate varied from day to day, but there were none in which Goldstein was not the principal figure...Goldstein was delivering his usual venomous attack upon the doctrines of the Party--an attack so exaggerated and perverse that a child should have been able to see through it, and yet just plausible enough to fill one with an alarmed feeling... Before the Hate had proceeded for thirty seconds, uncontrollable exclamations of rage were breaking out from half the people in the room ...In its second minute, the Hate rose to a frenzy. People were leaping up and down in their places and shouting at the tops of their voices in an effort to drown the maddening bleating voice that came from the screen ...The Hate rose to its climax. The voice of Goldstein had become an actual sheep's bleat, and for an instant the face changed into that of a sheep...

"Using this technique, Democrats so successfully conditioned the public to hate George Bush that even Republicans avoided being associated with him. Irrational Anti-Bush hatred was a major factor in Obama's campaign strategy.

Apparently, Obama intends to use the same technique to undermine any future Republican opposition to his plans. As Karl Rove has pointed out, Obama is already attributing false viewpoints and statements to nameless "straw men" whom he identifies as his opponents. This straw man attack may be an attempt to divert attention from the embarrassment of his numerous discredited nominees such as Richardson, Daschle, and Ron Kirk. It may also serve distract the public from noticing that the golden idol of O is beginning to turn green in places.

But this is a rather transparent trick that can't be used for long. With Bush retired from public life, Obama needs a new scapegoat. Evidently, Rush Limbaugh has been chosen. Calling him "the voice and the intellectual force and energy behind the Republican Party," White House Chief of Staff Rahm Emanuel is obviously trying to set up Limbaugh as the next hate icon for the minions of Big Other. Simultaneously, vicious attacks on Limbaugh were launched from several Democratic sources. It has been claimed that Obama's strategists are making an explicit effort to 'turn the [image of the] Republican Party into a Limbaughesque caricature.'"

Bush, Palin, Joe the Plumber, Limbaugh....and on it goes.