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Citizenship 153

for example, they argue that what is important is the way in which
perceived differences are used to make a social difference between the
sexes as stereotypical mothers and fathers of children. Furthermore, social
constructionists contend that there are social differences between women
in this respect which are as important as those between men and women.
Linda Nicholson (1983) , for example, discusses how white women in
nineteenth - century America were excluded from public activities and con-

fined to the home in order to maximize their capacities to bear children,
while, as soon as they were no longer commodities to be bought and sold,
black children were much less valued and black women were socially
positioned as menial workers. As a result, she argues, the orientation

toward care analyzed by Gilligan as specific to women would more appro-
priately be applied to white women in a particular, historically specifi c
situation; women, as such, do not have a “ different voice, ” since women
do not speak with a single voice at all (Nicholson, 1983 ). Nevertheless,
as Fuss argues, although social constructionists oppose “ real essentialism, ”
the perspective retains a degree of – unacknowledged – “ nominal essen-
tialism ” insofar as they continue to classify the world as divided into
“ men ” and “ women. ” As she puts it, “ Some minimal point of commonal-
ity and continuity necessitates at least the linguistic retention of these
particular terms ” (Fuss, 1989 : 4). Although “ women ” are treated as a
heterogeneous social group, rather than as a “ natural kind, ” there is,
nevertheless, the assumption that such a group can, and should, be seen
as sociologically relevant.
The importance of Fuss ’ s distinction becomes evident when we look at
the issue of political rights. It has been argued by feminists that, given the
under - representation of women in political institutions, women need
special rights in order to achieve equality with men in this respect. Anne
Phillips, one of the most prominent proponents of this view, puts forward
the argument that there should be quotas to increase women ’ s presence
in the political process in order to enable them to influence policies affect-

ing women (Phillips, 1991, 1995 ). Phillips actually explicitly rejects essen-
tialism on the grounds that women are not all the same and do not share
the same interests. Furthermore, her argument is not that women in politi-
cal institutions should be seen as representing women. As she points out,
representation in liberal democracies is based on geographical area or, in
the case of proportional representation, on promises of action, not on the
direct representation of social groups. In fact, such representation is
impossible if the category “ women ” is seen in pluralist terms, as a het-
erogeneous group of cross - cutting and even conflicting identities: speaking

in the name of “ women ” could only mean favoring some and excluding