Capitalize the bare “constitution”

Warning²Federal courts, Illinois courts21st and 22nd editions

A reference to the U.S. Constitution takes a capital, and a bare back-reference is still that reference; a document naming any other constitution is left alone.¹

1. 1R. 8(d)(ii) Exceptions; R. 8(c)(ii) Exceptions.
2. 2A warning: the form is usually wrong under the rule in note 1, and context can justify it.