Critical Race Theory (CRT) arose as a legal approach to address racial invisibility, exploitation, and injustice in the early 1980s and 1990s. It emerged in dissension with the Critical Legal Studies (CLS) movement. CLS, which came into existence alongside the Civil Rights movements of the 1960s and 1970s, took issue with the notion that law was marked by historical progress. CLS emerged from the tradition of Legal Realism of Justice Oliver Wendell Holmes, as well as from Marxian notions of “the radical contingency of law” (Belliotti 1995: 23). Critical Legal scholars argued that rather than being marked by historical progress, law was a form of political legitimation and ideology and was radically indeterminate rather than objective (Belliotti 1995: 27). Correspondingly, justice was elusive and should be sought by any and all means at one’s disposal. For Critical Legal scholars, law and politics were the same.