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===Additional critical perspectives=== Some formal models based on [[graph theory]] attempt to explore the implications of suppressed [[dissent]] and subsequent sabotage of the group as it takes action.<ref>{{cite book |pages=2841β2846 |doi=10.1109/ICSMC.2010.5641917 |chapter=Consensus building and the Graph Model for Conflict Resolution |year=2010 |last1=Inohara |first1=Takehiro |title=2010 IEEE International Conference on Systems, Man and Cybernetics |s2cid=36860543 |isbn=978-1-4244-6586-6 }}</ref> High-stakes decision-making, such as judicial decisions of appeals courts, always require some such explicit documentation. Consent however is still observed that defies factional explanations. Nearly 40% of the decisions of the [[United States Supreme Court]], for example, are unanimous, though often for widely varying reasons. "Consensus in Supreme Court voting, particularly the extreme consensus of unanimity, has often puzzled Court observers who adhere to ideological accounts of judicial decision making."<ref>{{cite journal|title=The Norm of Consensus on the U.S. Supreme Court|journal=American Journal of Political Science|volume=45|issue=2|pages=362β377|jstor = 2669346|last1 = Epstein|first1 = Lee|last2=Segal|first2=Jeffrey A.|last3=Spaeth|first3=Harold J.|year=2001|doi=10.2307/2669346}}</ref> Historical evidence is mixed on whether particular Justices' views were suppressed in favour of public unity.<ref>{{cite journal|title=Consensus, Disorder, and Ideology on the Supreme Court | doi=10.1111/j.1740-1461.2011.01249.x | volume=9|issue=1|journal=Journal of Empirical Legal Studies|pages=129β148|year = 2012|last1 = Edelman|first1 = Paul H.| last2=Klein | first2=David E. | last3=Lindquist | first3=Stefanie A. | s2cid=142712249 }}</ref> Heitzig and Simmons (2012) suggest using random selection as a fall-back method to strategically incentivize consensus over blocking.<ref name="SCFC" /> However, this makes it very difficult to tell the difference between those who support the decision and those who merely tactically tolerate it for the incentive. Once they receive that incentive, they may undermine or refuse to implement the agreement in various and non-obvious ways. In general [[voting system]]s avoid allowing offering incentives (or "bribes") to change a heartfelt vote. In the [[Abilene paradox]], a group can unanimously agree on a course of action that no individual member of the group desires because no one individual is willing to go against the perceived will of the decision-making body.<ref>{{cite journal|first=Jerry B.|last= Harvey|journal=Organizational Dynamics|date=Summer 1974|volume= 3|issue=1|title=The Abilene Paradox and other Meditations on Management|doi=10.1016/0090-2616(74)90005-9|pages=63β80}}</ref> Since consensus decision-making focuses on discussion and seeks the input of all participants, it can be a time-consuming process. This is a potential liability in situations where decisions must be made speedily, or where it is not possible to canvass opinions of all delegates in a reasonable time. Additionally, the time commitment required to engage in the consensus decision-making process can sometimes act as a barrier to participation for individuals unable or unwilling to make the commitment.<ref>{{cite web|url=http://www.au.af.mil/au/awc/awcgate/ndu/strat-ldr-dm/pt3ch11.html |archive-url=https://web.archive.org/web/20030427202741/http://www.au.af.mil/au/awc/awcgate/ndu/strat-ldr-dm/pt3ch11.html |url-status=dead |archive-date=27 April 2003 |title=Consensus Team Decision Making |access-date=17 January 2007 |work=Strategic Leadership and Decision Making |publisher=National Defense University }}</ref> However, once a decision has been reached it can be acted on more quickly than a decision handed down. American businessmen complained that in negotiations with a Japanese company, they had to discuss the idea with everyone even the janitor, yet once a decision was made the Americans found the Japanese were able to act much quicker because everyone was on board, while the Americans had to struggle with internal opposition.<ref>{{cite book |last1=Tomalin |first1=Barry |last2=Knicks |first2=Mike |title=The World's Business Cultures and How to Unlock Them |chapter=Consensus or individually driven decision- |publisher=Thorogood Publishing |year=2008 |page=109 |isbn=978-1-85418-369-9}}</ref>
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