Constitutional carry means carry without a license being required. Like in Vermont.What do you mean by "Constitutional carry" ? You mean OPEN carry (not concealed) ?
The term is usually used to refer to concealed carry, but I don't see why it could not also refer to unlicensed open carry.
I'm not sure how the term was coined. One moment no one used the term. And then the next moment from out of the blue suddenly everyone was using it.