Use the full citation or “id.”

Error²Federal courts, Illinois courts21st and 22nd editions

A constitution takes no short citation form apart from “id.”, so “supra” cannot stand for one; the citation is written out again, or “id.” used where the constitution is the authority just before.¹

1. 1R. 11 Constitutions; R. 20.7(b) Constitutions. Tables: R. 4.2 “Supra” and “Hereinafter”.
2. 2An error: the rule in note 1 allows one form, and this is not it.