 Grofman and Feld fan worries about deliberation by attributing to Rousseau the view that “each voter is polled about his or her independently reached choice, without any group deliberation” (1988: 570). Unsurprisingly, since many democratic theorists see public deliberation as instrumentally or intrinsically valuable, the proposal to sacrifice deliberation for independence was not met with enthusiasm. Recent debates in democratic theory, however, have turned to conditional notions of independence which can better accommodate deliberation and fruitful exchange, thereby also avoiding the controversial infallibility conclusion (cf.  Section 2  and  Section 4.5).