 Some philosophical intimation of a social model approach to cognitive disability can be found in Dan Wikler’s 1979 essay, “Paternalism and the Mildly Retarded”. Wikler held that the category of cognitive disability was socially constructed by the competence thresholds set for important social activities, such as signing a contract or voting in an election. But although society chooses, in this sense, who will be cognitively impaired, it does not have unlimited flexibility, since there can be significant social costs in altering those thresholds. The issue, Wikler concluded, was ultimately one of justice; of fairly distributing the burdens of setting thresholds that will be too high for some or too low for others. Yet Wikler questioned whether justice would require, or even permit, the kind of modifications necessary for significantly greater participation. Writing two decades later, Wolff cited Wikler in stating, 