 Estlund (2008) has raised a challenge against fairness-based versions of democratic proceduralism. He points out that other decision-making procedures—flipping a coin, for example—also satisfy a fairness requirement. An argument from fairness is thus insufficient to establish the superior legitimacy of democratic decision-making. Pure proceduralists can respond to this challenge by pointing to the distinctive fairness of democratic decision-making procedures. Christiano and Kolodny, for example, argue that the legitimacy of democratically made decisions stems from the kind of political equality that democracy, and only democracy, constitutes. According to Christiano (2008), only in a democracy are people publicly treated as equals. According to Kolodny (2014a, b), only a democracy offers the kind of equal opportunity to influence decision-making that avoids subordinating some to the decisions of others.