by J Mansbridge · 1999 · Cited by 2844 — Disadvantaged groups gain advantages from descriptive representation in at least four contexts. In contexts of group mistrust and uncrystallized interests,
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ARTICLESShould Blacks Represent Blacks and WomenRepresent Women? A Contingent “Yes”Jane MansbridgeHarvard UniversityDisadvantaged groups gain advantages from descriptive representation in at least four contexts. Incontexts of group mistrust and uncrystallized interests, the better communication and experientialknowledge of descriptive representatives enhances their substantive representation of the group’s in- terests by improving the quality of deliberation. In contexts of historical political subordination andlow de facto legitimacy, descriptive representation helps create a social meaning of “ability to rule”and increases the attachment to the polity of members of the group. When the implementation of de-scriptive representation involves some costs in other values, paying those costs makes most sense in these specific historical contexts.In at least four contexts, for four different functions, disadvantaged groups maywant to be represented by “descriptive representatives,” that is, individuals whoin their own backgrounds mirror some of the more frequent experiences and out-ward manifestations of belonging to the group. For two of these functionsŠ(1)adequate communication in contexts of mistrust, and (2) innovative thinking in contexts of uncrystallized, not fully articulated, interestsŠdescriptive represen- tation enhances the substantive representation of interests by improving the quality of deliberation. For the other two functionsŠ(1) creating a social mean-ing of “ability to rule” for members of a group in historical contexts where thatability has been seriously questioned, and (2) increasing the polity’s de facto le- gitimacy in contexts of past discriminationŠdescriptive representation promotes goods unrelated to substantive representation.In the contexts of group mistrust, uncrystallized interests, a history suggestinginability to rule, and low de facto legitimacy, constitutional designers and in-This article was completed while the author was a Fellow at the Center for Advanced Study in theBehavioral Sciences. I am grateful for financial support provided by the National Science FoundationGrant #SBR-9601236 and the Institute for Policy Research at Northwestern University. I am alsograteful for excellent suggestions, on versions of this and a more comprehensive study, from WilliamBianco, Carol Swain, Melissa Williams, Iris Marion Young, and participants in seminars at the Ohio State University, Nuffield College, Indiana University, Princeton University, the University ofCalifornia at San Diego, Harvard University, Northwestern University, and Boston College. I would particularly like to thank Benjamin Page for his close reading and incisive comments on that work.THE JOURNAL OF POLITICS, Vol. 61, No. 3, August 1999, Pp. 628-57© 1999 by the University of Texas Press, P.O. Box 7819, Austin, TX 78713-7819

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Should Blacks Represent Blacks and Women Represent Women? 629dividual voters have reason to institute policies that promote descriptive repre-sentation, even when such implementation involves some losses in theimplementation of other valued ideals. As political parties, legislative commit-tees, and voters weigh the pros and cons of descriptive representation, thisanalysis argues for attention to the specific historical contexts that make descrip-tive representation most useful.The analysis will stress that the deliberative function of democracy requires de-scriptive representation far more than does the aggregative function. It is primarilywhen we ask how to improve deliberationŠboth vertically, between constituent andrepresentative, and horizontally, among the representativesŠthat we discover the virtue of shared experience, which lies at the core of descriptive representation.What Is “Descriptive” Representation?In “descriptive” representation, representatives are in their own persons andlives in some sense typical of the larger class of persons whom they represent.1Black legislators represent Black constituents, women legislators representwomen constituents, and so on.Few commentators have noticed that the word “descriptive,” modifying repre-sentation, can denote not only visible characteristics, such as color of skin orgender, but also shared experiences, so that a representative with a background infarming is to that degree a descriptive representative of his or her farmer con-stituents. This criterion of shared experience, which one might reasonably expectto promote a representative’s accurate representation of and commitment to con-stituent interests, has a long history in folkways and even in law. Long-termresidents in a town often argue for electing to office someone born in the town onthe implicit grounds that lifetime experience increases the representative’s com- mon experiences with and attachment to the interests of the constituents. Similar arguments appear against “carpetbaggers” in state legislatures. The United States Constitution even requires that a president of the nation be born in the UnitedStates. “Being one of us” is assumed to promote loyalty to “our” interests.Arguments against Descriptive RepresentationDescriptive representation is not popular among normative theorists. Indeed,most normative democratic theorists have rejected descriptive representation rela-tively summarily, often with some version of Pennock’s trenchant comment, “Noone would argue that morons should be represented by morons” (Pennock 1979,’Birch 1993, 72; see also 1964, 16. The term “descriptive representation” was coined byGriffiths and Wollheim (1960, 188) and adopted by Pitkin ([1967] 1972). I use this term instead ofthe simpler “mirror” representation because of a potential confusion: Many people expect repre- sentatives of all kinds to “mirror” the views of their constituents. In the two best recent treatmentsof the issue, Phillips (1995) uses the term “politics of presence” and Williams (1998) the term “self-representation.”

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630 Jane Mansbridge314, based on Griffiths and Wollheim 1960,190; see also Grofman 1982,98; Pitkin[ 1967] 1972, chap. 4). Even among explicit advocates of group representation theideal of descriptive representation finds little support. Will Kymlicka writes, “[T]hegeneral idea of mirror [descriptive] representation is untenable” (1995, 139) andIris Marion Young concurs: “Having such a relation of identity or similarity withconstituents says nothing about what the representative does” (1997, 354).Empirical political scientists studying women and Black legislators have hadsimilar negative assessments. Irene Diamond, the first empirical political scien-tist to investigate in depth the actions of women legislators, reported, forexample, that in New Hampshire, the state with the highest percentage (and also the highest absolute number) of women legislators, most women legislators did not see themselves as “acting for” women, in Pitkin’s phrase. Rather, NewHampshire’s low salary ($200 a year in 1972) and high representative/constituent ratio (with its consequent low competitiveness) brought to the legislature a high proportion of older homemakers. With little self-confidence or desire for a careerin politics, they did not see themselves as representing women’s interests(Diamond 1977). On the basis of this kind of evidence, women political scien-tists often concluded that descriptive female gender had no predictable relation to support for women’s substantive interests (e.g., Schlozman and Mansbridge1979).2 The first empirical political scientist to investigate in depth the actions ofBlack members of Congress, Carol Swain, similarly concluded that in the U.S.Congress, “[m]ore black faces in political office (that is, more descriptive repre-sentation for African Americans) will not necessarily lead to more representationof the tangible interests of blacks” (1993, 5).These normative theorists and empirical researchers make an important, in-controvertible point. The primary function of representative democracy is to represent the substantive interests of the represented through both deliberationand aggregation. Descriptive representation should be judged primarily on this criterion. When nondescriptive representatives have, for various reasons, greater ability to represent the substantive interests of their constituents, this is a major argument against descriptive representation.The Costs of a Lottery: Lesser TalentThe most frequent criticism of descriptive representation charges that descrip-tive representatives will be less able than others to perform the task of the2Sapiro (1981, 712), however, argued that in the case of women descriptive representation was “anecessary condition, but it is not sufficient.” Her argument for necessity rested on the grounds that(1) having women rather than men in office demonstrably makes government somewhat more re-sponsive to women’s interests; (2) participation in government is intrinsically valuable; and (3) increased representation of women will undermine the perception that politics is a male domain. Iwill reproduce most of these arguments here, while both moving them from the domain of necessity to contingency and agreeing that the contingent circumstances that make some descriptive represen- tation beneficial for women obtain now.

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Should Blacks Represent Blacks and Women Represent Women? 631substantive representation of interests: “No one would argue that morons shouldbe represented by morons.”This criticism rests primarily on confusing two forms of descriptive rep-resentation, the “microcosmic” and the “selective” forms.3 In “microcosmic”representation, the entire assembly is designed to form a microcosm, or repre-sentative sample, of the electorate. Microcosmic representation was the ideal ofJohn Adams, James Wilson, Mirabeau, and certain other eighteenth-centurytheorists (Pitkin [1967] 1972), including particularly the American Anti-Federalists (Manin [1995] 1997, 109-14). Almost all of Hanna Pitkin’sargument against descriptive representation, which has often been taken as dis-positive, is explicitly or implicitly directed against this form (Pitkin [1967]1972, chap. 4).If microcosmic representation, achievable only by lottery or another form ofrepresentative selection, were to replace elected representative assemblies, onecost would indeed lie in the strong likelihood that choosing the members of aruling assembly at random from the population would produce legislators withless ability, expertise, and possibly commitment to the public good than wouldchoosing those legislators through election. In current electoral systems, many ofthose who run for election have chosen lawmaking as their vocation. They havespent much of their adult lives acquiring the skills needed for the job. The votersthen select among these individuals, guided in part by the ability and training of the candidates in their chosen field. Representatives so selected arguably havegreater abilities and training in this field than individuals selected through a rep-resentative sample.4 Representatives who have chosen politics as a calling andwho have been selected in competitive elections may also have a greater com-mitment to the public good than individuals chosen through a representativesample (see Madison [1788] 1987), although some election and reelection incen- tives work in the opposite direction.My own experience with town meeting democracy (Mansbridge [1980] 1983)leads me to conclude that the ability, expertise, and commitment to the publicgood of ordinary members of the public are sufficient to make a relatively random3The term “microcosmic” comes from Birch 1993, 72; the term “selective” is my own.”Burnheim’s (1985) suggestions for microcosmic representation reduce the potential costs oflesser talent with a process based on a mixture of nomination and lot. Manin ([1995] 1997) traces thedifferent uses of lot in the political systems of ancient Greece, Rome, and the Italian republics of theRenaissance, specifying in each case the mechanisms that increased the likelihood of competent and responsible action on the part of the officeholder chosen by lot. He plausibly attributes the relatively sudden disappearance in the eighteenth century of political interest in the lot both to a concern thatcitizen consent be expressed in electoral participation andŠamong many writers in England, France, and the Federalists in AmericaŠto a desire for representatives to rank higher than most of their con-stituents in talent, virtue, and wealth. Representation by some forms of lot, he argues, was practicable even in polities as large as those of eighteenth-century England (82). For a general discussion of the uses of randomization, see Elster [1987] 1989.

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632 Jane Mansbridgesample of citizens a plausible, although by no means ideal, representative as-sembly. In contrast to Pitkin, who argued that there is simply “no room” in adescriptive concept of representation for “leadership, initiative or creative action”([1967] 1972, 90), I do not find it hard to envision a representative sample of theU.S. population producing the kind of leadership, initiative, and creative actionof which the average New England town meeting is capable. The capacities ofsuch leaders, initiators, and creators would undoubtedly not reach the level ofthose who now guide the United States, but I am not sure that they would be in-capacitatingly worse.Nevertheless, because lawmaking in large states and at the national level usu-ally requires considerable talent and acquired skill, the costs of replacing currentelected assemblies with assemblies chosen simply by random selection from the population overwhelm the current benefits. Very few democratic theorists advo-cate substituting microcosmic representation for electoral representation. Eventhe Australian John Burnheim, who advocates microcosmic representation basedon a modified lot, does not expect his suggestion to be put into practice withinour lifetimes in any of the world’s current democracies. The suggestions with agreater likelihood of being adopted add to existing electoral systems some com- ponent of microcosmic representation.5In the far more frequent “selective” form of descriptive representation, insti-tutional design gives selected groups greater descriptive representation than they would achieve in existing electoral systems in order to bring the propor-tions of those groups in the legislature closer to their percentages in thepopulation. Selective forms of descriptive representation are necessary, if at all,only when some form of adverse selection operates within an existing systemto reduce the proportions of certain groups below what they would achieve bychance. Otherwise, one would expect all the characteristics of the population tobe duplicated, more or less, in the legislature in proportion to their occurrencein the population. Selective representation should thus be conceived as com– Mueller, Tollison. and Willett (1972), Barber (1984, 290-93), and Callenbach and Phillips (1985)have proposed election of officials by lot, but not with the expectation of having their suggestionswidely adopted. Dahl (1970, 149; 1977, 17; 1985, 86-89; 1992, 54-57) has suggested adding a thirdassembly, chosen by lot from a nationwide population, to advise the United States Senate and Houseof Representatives. More recently Dahl has suggested creating smaller deliberative bodies, drawn bylot from a nationwide population, to consider specific issues, such as health care, in which the re-election incentives of politicians and the desire among the populace to benefit without paying costscombine to curtail appropriate deliberation (Dahl 1997). These bodies are similar to Nagel’s (1992)”deliberative assemblies] on a random basis” (DARBs), Fishkin’s (1991, 1995, 1996) “deliberativeopinion polls.” and Crosby’s (1995, 1996) more local “citizen juries,” the last two of which have al-ready developed a notable track record in practice. None of these theorists advocating forms ofmicrocosmic representation has, however, either used the terms “descriptive” or “mirror” representa- tion, or evaluated their recommended microcosmic forms in explicit response to the literature critical of descriptive representation.

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Should Blacks Represent Blacks and Women Represent Women? 633pensating for the effects of some other process that interferes with an expectedproportionality.One version of the selective form of representation draws geographical districtlines to encourage the election of representatives from proportionally underrep-resented groups. In other versions of selective representation, parliaments andparties set aside a number of seats for members of specific descriptive groups, suchas French speakers, Catholics, scheduled castes, or women. Other versions couldseek to identify and mitigate or remove on a more universalist basis particularobstacles that now account for some of the underrepresentation of certain groups.Representatives with selective descriptive characteristics need not be signifi-cantly less skilled or dedicated to the public good than representatives chosen forreasons that do not include descriptive characteristics. It is true that adding anycriterion (e.g., that a representative have lived in a constituency five or moreyears, or be of a given gender or ethnicity) to a mix of criteria for selection willalways dilute to some degree the impact of the other criteria for selection. Thekey question is, however, whether the reasons for the currently lower proportion of a given characteristic are functionally related to ability to perform the task of representation. Such lowered ability could be the reason that in the existing sys- tem those characteristics have been selected against (as in the case of “morons”).But if the reasons for lower proportions of the characteristic are not functionallyrelated to the task, and if the descriptive characteristic on which one is selecting is widely shared, one would expect any decrement in talent from adding a descrip-tive-criterion to the mix of criteria for selection to be almost infinitesimally small.6The institutional tools that have recently been used to promote relevant de-scriptive representation (e.g., redrawing district lines in the United States orchanging the composition of party lists in Europe) do not seem to have resultedin representatives with noticeably lesser skills or commitment to the public good.Although in microcosmic representation the costs in talent might be consider-able, in selective representation those costs seem to be negligible.The Costs of Selection: Which Groups, Why, and How Many from Each?If microcosmic representation has the cost of some likelihood of lesser talent,at least it has no costs derived from having to choose some groups rather thanothers for descriptive representation. Selective representation presents exactlythe opposite pattern. The cost in lesser talent is relatively low, but costs do arise6 If adding descriptive criteria in fact made a selection process dip significantly lower into the poolof potential reprentatives, polities could compensate for any expected descriptive decrement by re-ducing the negative impact of the other factors on selection (e.g., by instituting public funding forcampaigns or increasing the salary of the legislators). The number of talented and dedicated individ- uals currently driven away from state and federal electoral politics by low salaries and the politically compromising activities of fund-raising is undoubtedly far higher than the number that would beoverlooked if, say, ethnicity and gender played greater roles in the selection process.

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Should Blacks Represent Blacks and Women Represent Women? 635sharing, and with strong protections for minority rights, it comes sufficientlyclose.9This analysis allows us to conclude that the perspectives and interests ofleft-handers should be represented in deliberation when their perspectives arerelevant to a decision (e.g., in decisions regarding the design of surgical in-struments) and in aggregation when their interests conflict with those ofothers. Similarly with redheads, Lithuanians, Italians, Jews, the uneducated, andall other groups.In aggregation, interests are relatively easily represented by nondescriptiverepresentatives. If a right-handed representative will suffer sufficiently in the next election from not voting for left-handers’ interests, that incentive is by de- finition enough to make the representative cast the normatively appropriatevote. It is true that being a left-hander oneself helps produce internal commit-ment to the struggle, so that when the issue requires more than just casting a vote (e.g., when it requires preparing, proposing, and gathering support for leg-islation), left-handed representatives will usually be more likely to throwthemselves into the fray. But on matters of pure aggregation, reelection incen- tives and other forms of accountability can make descriptive representation unnecessary. For aggregation alone, normative democratic theory demands onlythat power be exercised on behalf of particular interest bearers in proportion to their numbers in the population, not that this power be exercised by any partic- ular mechanism.In deliberation, perspectives are less easily represented by nondescriptiverepresentatives. Through reading, conversation, and living with left-handers,right-handers can learn many of the perspectives of this group that would be relevant to a deliberation. As we will see, however, in the contexts of com- municative mistrust and uncrystallized interests this vicarious portrayal of the experience of others by those who have not themselves had those experi- ences is often not enough to promote effective deliberationŠeither vertically between constituents and their representatives or horizontally among the representatives. Although a representative need not have shared personally the experiences of the represented to facilitate communication and bring subtlety to a deliberation, the open-ended quality of deliberation gives communicative9 The questions of which perspectives will contribute to understanding and which interests conflictwill often be contested, as will the question of how close in any given case an issue comes to eithercommon or conflicting interests. Moreover, the ideals of achieving understanding and settling con-flict legitimately are always “regulative” idealsŠthat is, ideals at which one should aim but notexpect fully to achieve (see Mansbridge 1996 on actual polities never achieving full democratic le-gitimacy). Giving any group veto power over issues deeply important to that group can be useful in a compromise instituting some form of cooperative self-rule when cooperation would otherwise not take place, but such vetoes favor the status quo in inegalitarian ways. Restricting such vetoes to dis- advantaged groups (Young 1990) raises the thorny question of how to define which groups deserve such a veto (Kymlicka 1995, 145: Phillips 1992, 89; Williams 1998, 198).

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636 Jane Mansbridgeand informational advantages to representatives who are existentially close tothe issues.10Do deliberations require the participation of representatives of relevant per-spectives in proportion to the incidence of those perspectives in the population? In theory, deliberation seems to require only a single representative, or a “thresh-old” presence, in the deliberation to contribute to the larger understanding (Kymlicka 1993, 77-78, 1995, 146^7; Mansbridge 1981; Phillips 1995, 47,67ff.; Pitkin [1967] 1972, 84). Getting the relevant facts, insights, and perspec-tives into the deliberation should be what counts, not how many people advance these facts, insights, and perspectives. In practice, however, disadvantagedgroups often need the full representation that proportionality allows in order to achieve several goals: deliberative synergy, critical mass, dispersion of influence, and a range of views within the group.First, deliberation is often synergistic. More representatives usually producemore, and sometimes better, information and insight, particularly when they may need to explore among themselves new ideas that counter the prevailing wisdom. Groups whose members will be affected by a decision might therefore legiti- mately demand, even under deliberative criteria, as many representatives as reflect their numbers in the population.Second, representatives of disadvantaged groups may need a critical mass fortheir own members to become willing to enunciate minority positions. They mayalso need a critical mass to convince othersŠparticularly members of dominantgroupsŠthat the perspectives or insights they are advancing are widely shared, genuinely felt, and deeply held within their own group.Third, governing bodies usually include a variety of committees and subcom-mittees in whose deliberative spaces the most important features of policy are often hammered out. Having sufficient numbers of representatives to disperseinto the relevant policy areas allows members of the disadvantaged group to in- fluence decisions wherever those decisions would become better decisions by including these members’ perspectives.Finally and most importantly, because the content and range of any delibera-tion is often unpredictable, a variety of representatives is usually needed to represent the heterogeneous, varied inflections and internal oppositions that to- gether constitute the complex and internally contested perspectives, opinions, and interests characteristic of any group. This range of views is not easily repre-sented by only a few individuals.This analysis suggests that African Americans in the United States are farmore richly represented deliberatively by a Congress that includes William GrayIII (a Black member of Congress who did not support the Congressional Black'”Pitkin’s ([1967] 1972) condemnation of descriptive representation recognized its uses in delib-eration, but set up what I believe to be a false dichotomy between “talking” and “actively governing”(63, 84), as well as sometimes seeming to restrict the deliberative function to simply “giving infor-mation” (63, 81, 83, 84, 88,90).

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Should Blacks Represent Blacks and Women Represent Women? 637Caucus’s alternative budget because he was chairman of the Budget Committeein the House) and George Crockett (a Black member of Congress who con-demned the State Department for refusing to grant Yasir Arafat an entry visa)than by a Congress that included only one of these two.” No matter how purelydeliberative the assembly, reasons of synergy, critical mass, helpful dispersionand internal diversity insure that in practice each group will usually want to claim as many representatives on that body as is justified by proportionality.The demand for proportionality is accentuated by the fact that in practice al-most all democratic assemblies are aggregative as well as deliberative, and achieving the full normative legitimacy of the aggregative function requires that the members of the representative body cast votes for each affected conflictinginterest in proportion to the numbers of such interest bearers in the population(see Mansbridge 1981, 1996, 1998 for a fuller exposition of these ideas).”Essentialism” as a Cost of SelectionThe greatest cost in selective descriptive representation is that of strengthen-ing tendencies toward “essentialism,” that is, the assumption that members ofcertain groups have an essential identity that all members of that group share andof which no others can partake. Insisting that women represent women or Blacks represent Blacks, for example, implies an essential quality of womanness orBlackness that all members of that group share. Insisting that others cannot ad-equately represent the members of a descriptive group also implies that membersof that group cannot adequately represent others (Kymlicka 1993, 1995; Phillips1992, 1995; Swain 1993; Young 1997).This problem of essentialism haunts every group that hopes to organize polit-ically around a facet of identity, including descriptive characteristics such asplace of birth, gender, and race. Essentialism involves assuming a single or es-sential trait, or nature, that binds every member of a descriptive group together, giving them common interests that, in the most extreme versions of the idea,transcend the interests that divide them. Such an assumption leads not only to re-fusing to recognize major lines of cleavage in a group, but also to assimilatingminority or subordinate interests in those of the dominant group without even recognizing their existence (Fuss 1989; Spelman 1988; see Young 1994, 1997 for ways of conceiving of group existence with a minimum of essentialist thinking). The problem is exacerbated when the facets of identity assumed to bind the”See Swain 1993, 41, 49-71, for Gray and Crockett, and passim for the diversity in opinions andstyles within the spectrum of African American representation in Congress in the 1980s and early1990s. See Young 1997 for the concept of diversity of opinion within a single “perspective.” For bothdeliberative and aggregative purposes, the full diversity within any larger perspective or interestshould ideally be represented in proportion to numbers in the population, subject to the critical de-liberative limitations of (1) threshold representation when a useful perspective would otherwise notbe represented at all in a proportional distribution (Kymlicka 1995, 147) and (2) the winnowing outand reduction in salience of relatively harmful and useless ideas.

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638 Jane Mansbridgegroup together have biological markers, such as sexual organs or skin color,because such markers encourage seeing whatever commonalities are assumedcentral to the group as biological, not historical.At its most basic, of course, the process of thought itself encodes a form of es-sentializing. Most of us cannot think “table” without unconsciously conjuring upa four-legged brown piece of furniture, thereby marginalizing in our considera-tions the many tables with more or fewer legs and different colors. The problemof simple categorization becomes much worse when, as is often the case in hu-man affairs, one group is socially dominant and becomes the norm, settingexpectations and structuring institutions so that those who do not conform to that norm are perceived as deviant or lesser beings, perceive themselves as deviant,and cannot function as well in the structures designed for the members of thedominant group.Even political groups based on descriptive identity that challenge the hegem-ony of the dominant group cannot escape this internal dynamic. Feministorganizations that appeal to “sisterhood” have portrayed that sisterhood primar-ily in terms that reflected the concerns of the dominant (White middle-class)groups in the movement (cf., e.g., Harris 1990; Spelman 1988). Black feministwriters who have challenged that dominance within feminism have themselves portrayed Black women as having a singular “Afrocentric standpoint” (e.g.,Collins 1990). Although human cognitive processes prevent our eliminatingthis tendency to assume homogeneity within a group, we can fight that tendencyby cultivating avenues of dissent, opposition, and difference within our orga-nizations, struggling to appreciate contradictions within a larger perceptualstandpoint, and using plurals rather than singulars in our writing.The advocacy of descriptive representation can emphasize the worst featuresof essentialism. When an extreme descriptivist writes, “it is impossible for mento represent women” (Boyle 1983, 797),12 that statement implies the corollary,that it is impossible for women to represent men. It also implies that any womanrepresentative represents all women (and all women equally), regardless of thewomen’s political beliefs, race, ethnicity, or other differences.The essentializing features of descriptive representation can be mitigated bystressing the nonessentialist and contingent reasons for selecting certain groupsfor descriptive representation. The entire argument in this article is an argumentfrom contingency. Building on a more general argument for the proportional rep- resentation of interests, it highlights the historical contexts in which descriptiverepresentation is likely to advance the substantive representation of interests.That descriptive representation most closely approaches normative ideals whenit reflects the inner diversity of any descriptively denominated group.12See also Phillips 1995, 52, quoting a group of Frenchwomen in 1789 (“a man, no matter howhonest he may be, cannot represent a woman”) and Williams 1998, 133, quoting the ReverendAntoinette L. Brown in 1852 (“Man cannot represent woman”).

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