The effectiveness of representation in a democracy depends upon how those authorized to govern remain accountable to those being governed for their policy decisions. Representation—whether pure or polluted, or some approximation thereof—depends upon the coincidence of three factors, factors to which the Supreme Court has had to give content over the certain years. First, constituency refers to what is being represented. Second, participation refers to how the constituency expresses its interests. Third, deputation refers to who is delegated to carry out the constituency's business. Translating constituency interests into policy demands that will be heeded takes at least three distinct forms—voting, the activities of political party organizations, and the efforts of interest groups. The evolution of representation as a viable constitutional component has been hesitant but inexorable. Federalism has tended to hinder its unfolding, while Congress and the Supreme Court have encouraged its movement toward a purer version of representation.