Abstract: In his Essay, Judicial Review of Direct Democracy, Professor Julian Eule argued powerfully for intensified judicial scrutiny for bill-of-rights violations of laws enacted by popular initiative. Professor Eule based his argument on the ways in which the Framers designed the republican form of government to depart from a pure democracy so as better to respect the basic rights and interests of the governed. Professor Frank Michelman carries Professor Eule's inquiry one step further, by questioning whether the democratic ideal itself-let alone a "republican" replacement for it-is realizable through direct democracy.