 During those years, the ACLU led the way in expanding legal rights in three directions: new rights for persons within government-run "enclaves", new rights for victim groups, and privacy rights for mainstream citizens. At the same time, the organization grew substantially. The ACLU helped develop the field of constitutional law that governs "enclaves", which are groups of persons that live in conditions under government control. Enclaves include mental hospital patients, members of the military, and prisoners, and students (while at school). The term enclave originated with Supreme Court justice Abe Fortas's use of the phrase "schools may not be enclaves of totalitarianism" in the Tinker v. Des Moines decision.
