 But recently scholars have widened the criticism. Nick Leonard (forthcoming) argues that, like the dead and dying, promisees who fail to have the standard cognitive capacity to rely on promises would certainly fail the uptake condition for expectational theories. He imagines in this role small children, or people with severe cognitive limitations. Such promisees are intuitively owed fidelity, but expectational promissory theories can’t accommodate this judgment, since the promisees don’t have the required uptake, i.e., they fail to form expectations or reliance. Further Leonard argues that joint commitment views are similarly cognitively demanding, requiring as they do complex and sophisticated mental states like mutual intentions.