 The second line of response to the criticisms of consent theory is to argue in one way or another that the critics construe “consent” too narrowly. Thus John Plamenatz (1968, “Postscript”) and Peter Steinberger (2004, p. 218) have maintained that voting or otherwise participating in elections should count as consent; and Steinberger produces a lengthy list of fairly ordinary activities – calling the police or fire department for help, sending children to a public school, using a public library, and more – that constitute “active participation in the institutions of the state” (pp. 219–20). Mark Murphy and Margaret Gilbert have sounded variations on this theme by arguing, in Murphy’s case, that “surrender of judgment is a kind of consent” (in Edmundson 1999, p. 320), or, in Gilbert’s, that “joint commitment” is an important source of obligations, including political obligations (1993, 2006, 2013). For Murphy, surrender of judgment is consent in the usual sense of voluntary agreement or acceptance. As he says, “One consents to another in a certain sphere of conduct in the acceptance sense of consent when one allows the other’s practical judgments to take the place of his or her own with regard to that sphere of conduct. (This consent may be either to a person or to a set of rules: both of these can be authoritative)” (p. 330). As the earlier discussion of her ideas indicates (§2.3), Gilbert differs from Murphy, and others, in taking a joint commitment to be something that need not arise voluntarily. According to her theory, “an understanding of joint commitment and a readiness to be jointly committed are necessary if one is to accrue political obligations, as is common knowledge of these in the population in question. One can, however, fulfill these conditions without prior deliberation or decision, and if one has deliberated, one may have had little choice but to incur them” (2006, p. 290). Indeed, membership in a “plural subject” formed through non-voluntary joint commitments plays such a large part in Gilbert’s theory that it may be better to place her with those who advocate an “associative” or “membership” theory of political obligation than with adherents of consent theory.