The founders of the American regime recognized that organizations existing outside of government would play a crucial role in the formulation and implementation of public policy. Although they feared the destructive power of factions-selfinterested persons who join with other like-minded individuals to pursue a goal based on a common interest or passion-they recognized, in the immortal words of “Federalist 10,” that the “latent causes of faction are thus sown in the nature of man.” If they could not prevent factions from forming, they must mitigate the effects of self-interest and passion lest such forces hobble or even destroy the republic. Despite their concerns, the Founders envisioned the centrality of group participation in debate and governance.2