 Bell (1964, [2004]) reasoned that any local hidden variable theory must yield conditional probabilities of 0 or 1 for each local outcome in order to reproduce all quantum predictions but could not permit these to depend on the choice of distant measurement. He then proved that the probabilistic predictions of any local hidden variable theory must satisfy particular inequalities violated by predictions of quantum theory for certain entangled state assignments (see entry  Bell’s Theorem).  In later work Bell (1990, [2004]) generalized this argument to apply to any theory of a certain type meeting a condition he called Local Causality which, he claimed, quantum mechanics does not meet. Howard (1989, 1992) took outcome independence — the probabilistic independence of the outcomes of a given pair of measurements, one on each of a pair of entangled systems, conditional on definite values for any assumed hidden variables on the joint system—as a separability condition. Outcome independence may be contrasted with parameter independence—the condition that, given a definite hidden variable assignment, the outcome of a measurement on one of a pair of entangled systems is probabilistically independent of what measurement, if any, is made on the other system. Together with parameter independence, outcome independence implies the factorization of conditional probabilities that leads to what are now called Bell inequalities. These inequalities constrain the patterns of statistical correlations to be expected between the results of measurements of variables such as spin and polarization on a pair of entangled systems in any quantum state. Quantum mechanics predicts, and experiment confirms, that such Bell inequalities do not always hold. The Bohm theory accommodates this fact by its violation of parameter dependence, and hence Local Causality. But Howard (1989), as well as Teller (1989), suggested that we appeal instead to a failure of outcome independence to understand why Bell inequalities do not always hold, and that this failure is associated rather with holism or nonseparability. Howard (1989) blamed the violation of Bell inequalities on the violation of his separability condition: Teller (1989) took it to be a manifestation of  relational holism.  They both acquit parameter independence of blame because they believe that (at least when the measurement events on the entangled systems are spacelike separated) parameter independence (unlike outcome independence) is a consequence of relativity theory: (note that the Bohm theory requires a preferred frame not provided by relativity theory).