 Another objection to the contractual view concerns voluntarism. Critics of the voluntarist approach to the family deny that family morality is exhausted by voluntary obligations (Sommers 1989). Voluntarist conceptions of the family conflict with common-sense intuitions that there are unchosen special duties between family members, such as filial duties. However, even if voluntarism is false, this does not suffice to establish special spousal duties. On the other hand, voluntarism alone does not entail the contractual view, for it does not entail that spouses can negotiate the obligations of marriage or that the obligations be subject to release, only that spouses must agree to them. Voluntarism, in other words, need not extend to the choice of marital obligations and hence need not entail the contractual account. The contractual account depends on denying that there is decisive moral reason for marriage to incorporate certain fixed obligations. Let us turn to the case that there is such reason.