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The set of critiques that has ignited perhaps the most intense debateabout multiculturalism argues that extending protections to minoritygroups may come at the price of reinforcing oppression of vulnerablemembers of those groups—what some have called the problem of“internal minorities” or “minorities withinminorities” (Green 1994, Eisenberg and Spinner-Halev 2005).Multicultural theorists have tended to focus on inequalitiesbetween groups in arguing for special protections forminority groups, but group-based protections can exacerbateinequalities within minority groups. This is because someways of protecting minority groups from oppression by the majority maymake it more likely that more powerful members of those groups areable to undermine the basic liberties and opportunities of vulnerablemembers. Vulnerable subgroups within minority groups include religiousdissenters, sexual minorities, women, and children. A group's leadersmay exaggerate the degree of consensus and solidarity within theirgroup to present a united front to the wider society and strengthentheir case for accommodation.

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Multicultural education is about more than a classroom with varied skin color.

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Mira Bachvarova has also argued for the merits of anon-domination-based multiculturalism as compared to liberalegalitarian approaches. Because of its focus on the arbitrariness ofpower and the broader structural inequalities within which groupsinteract, a non-domination approach may be more sensitive to powerdynamics in both inter-group and intra-group relations. Also, incontrast to approaches developed out of egalitarian theories ofdistributive justice that focus on distributing different types ofrights, a non-domination approach focuses on the “moral qualityof the relationship between the central actors” and insists oncontinuity of treatment between and within groups (2014, 671).

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Theorists adopting a postcolonial perspective go beyond liberalmulticulturalism toward the goal of developing models ofconstitutional and political dialogue that recognize culturallydistinct ways of speaking and acting. Multicultural societies consistof diverse religious and moral outlooks, and if liberal societies areto take such diversity seriously, they must recognize that liberalismis just one of many substantive outlooks based on a specific view ofman and society. Liberalism is not free of culture but expresses adistinctive culture of its own. This observation applies not onlyacross territorial boundaries between liberal and nonliberal states,but also within liberal states and its relations with nonliteralminorities. James Tully has surveyed the language of historical andcontemporary constitutionalism with a focus on Western state'srelations with Native peoples to uncover more inclusive bases forintercultural dialogue (1995). Bhikhu Parekh contends that liberaltheory cannot provide an impartial framework governing relationsbetween different cultural communities (2000). He argues instead for amore open model of intercultural dialogue in which a liberal society'sconstitutional and legal values serve as the initial starting pointfor cross-cultural dialogue while also being open to contestation.

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A second justification for multiculturalism comes from withinliberalism but a liberalism that has been revised through criticalengagement with the communitarian critique of liberalism. WillKymlicka has developed the most influential liberal theory ofmulticulturalism by marrying the liberal values of autonomy andequality with an argument about the value of cultural membership(1989, 1995, 2001). Rather than beginning with intrinsically valuablecollective goals and goods as Taylor does, Kymlicka views cultures asinstrumentally valuable to individuals, for two main reasons. First,cultural membership is an important condition of personal autonomy. Inhis first book, Liberalism, Community, and Culture (1989),Kymlicka develops his case for multiculturalism within a Rawlsianframework of justice, viewing cultural membership as a “primarygood,” things that every rational person is presumed to want andwhich are necessary for the pursuit of one's goals (Rawls 1971, 62).In his later book, Multicultural Citizenship (1995), Kymlickadrops the Rawlsian scaffolding, relying instead on the work of AvishaiMargalit and Joseph Raz on national self-determination (1990). Oneimportant condition of autonomy is having an adequate range of optionsfrom which to choose (Raz 1986). Cultures serve as "contexts ofchoice," which provide meaningful options and scripts with whichpeople can frame, revise, and pursue their goals (Kymlicka 1995, 89).Second, cultural membership plays an important role in people'sself-identity. Citing Margalit and Raz as well as Taylor, Kymlickaviews cultural identity as providing people with an “anchor fortheir self-identification and the safety of effortless securebelonging” (1995, 89, quoting Margalit and Raz 1990, 448 andalso citing Taylor 1992). This means there is a deep and generalconnection between a person's self-respect and the respect accorded tothe cultural group of which she is a part. It is not simply membershipin any culture but one's own culture that must be secured inorder for cultural membership to serve as a meaningful context ofchoice and a basis of self-respect.

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There has been a wave of feminist responses to the problem ofvulnerable internal minorities that is sympathetic to bothmulticulturalism and feminism (see, e.g., Arneil 2006b, Deveaux 2006,Eisenberg 2003, Phillips 2007, Shachar 2001, Song 2007, Volpp 2000).Some have emphasized the importance of moving away from essentialistnotions of culture and reductive views of members of minority groupsas incapable of meaningful agency (Phillips 2007, Volpp 2000). Othershave sought to move from the emphasis on rights in liberalmulticulturalism towards more democratic approaches. Liberal theoristshave tended to start from the question of whether and how minoritycultural practices should be tolerated or accommodated in accordancewith liberal principles, whereas democratic theorists foreground therole of democratic deliberation and ask how affected partiesunderstand the contested practice. By drawing on the voices ofaffected parties and giving special weight to the voice of women atthe center of gendered cultural conflicts, deliberation can clarifythe interests at stake and enhance the legitimacy of responses tocultural conflicts (Benhabib 2002, Deveaux 2006, Song 2007).Deliberation also provides opportunities for minority group members toexpose instances of cross-cultural hypocrisy and to consider whetherand how the norms and institutions of the larger society, whose ownstruggles for gender equality are incomplete and ongoing, mayreinforce rather than challenge sexist practices within minoritygroups (Song 2005). There is contestation over what constitutessubordination and how best to address it, and intervention intominority cultural groups without the participation of minority womenthemselves fails to respect their freedom and is not likely to servetheir interests.

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In reply, one might agree that opportunities are not objective in thestrong physicalist sense suggested by Barry. But the opportunity to doX is not just having the possibility to do X without facing physicalencumbrances; it is also the possibility of doing X without incurringexcessive costs or the risk of such costs (Miller 2002, 51). State lawand cultural commitments can conflict in ways such that the costs forcultural minorities of taking advantage of the opportunity areprohibitively high. In contrast to Barry, liberal multiculturalistsargue that many cases where a law or policy disparately impacts areligious or cultural practice constitute injustice. For instance,Kymlicka points to the Goldman case (discussed above) and otherreligion cases, as well as to claims for language rights, as examplesin which group-differentiated rights are required in light of thedifferential impact of state action (1995, 108–115). Hisargument is that since the state cannot achieve completedisestablishment of culture or be neutral with respect to culture, itmust somehow make it up to citizens who are bearers of minorityreligious beliefs and native speakers of other languages. Becausecomplete state disestablishment of culture is not possible, one way toensure fair background conditions is to provide roughly comparableforms of assistance or recognition to each of the various languagesand religions of citizens. To do nothing would be to permitinjustice.