 Advocates of group representation, like Iris Marion Young, have argued that some historically disenfranchised groups may still not do very well under proportional representation (Young 1990: ch. 6). They may not be able to organize and articulate their views as easily as other groups. Also, minority groups can still be systematically defeated in the legislature and their interests may be consistently set back even if they do have some representation. For these groups, some have argued that the only way to protect their interests is legally to ensure that they have adequate and even disproportionate representation.