Bickel wrote in the 1960s, the least dangerous branch in the us, the government has three branches: executive branch president and cabinet, congress, and judiciary branch. Sees judiciary branch as the least dangerous of the three. No one can elect the judges on the supreme court level. Judges understand the limitations of their power. Important to look at the practice of judicial review. Starts by outlining the problems of judicial review. Issue of democracy since judges are not elected it is not seen as reflecting the values of society therefore its not legitimate because the public cannot elect the judiciary. In the us, democracy is a series of factions who all have to work together, since the president does not have the power to make legislative decisions without the approval from congress. No majority but rather a series of minorities that have to communicate with each other to achieve common national goals.