Is There A \"Dog Whistle\" in Constitutional Conservatism?

According to Ed Kilgore at the New Republic, Michelle Bachmann's frequent and intentional self-labelling as a "constitutional conservative" can mean different things to different people, but that to those who hear the "dog whistle" in the words, the vision is a little scary.
This is why we have elections: To find out just what the candidates mean by their slogans and it will be interesting to watch the media try and pin down Bachmann on this score. To her great credit, Bachmann does not shy away from media interviews with media outfits other than Fox, so there will be plenty of opportunity to find out just how much of the the phrase is principled and how much is scary.
Attentive readers will also note Kilgore's reference to Peter Berkowitz whom I have cited before as one of the leading lights of intelligent, informed conservative thought writing in America today.