Perhaps the best-known argument that individual bureaucrats have an unavoidable policymaking role is Michael Lipsky’s Street-Level Bureaucracy: Dilemmas of the Individual in Public Services (1980). Lipsky’s central premise is that street-level bureaucrats—policemen, teachers, and the like—routinely have to make decisions that are not dictated by the mission of the organizations they work for, or the rules they are supposed to enforce. Street-level bureaucrats thus make policy as a result of their behavior. For example, no matter what the law says the speed limit is, in practice it is determined by the individual traffic cop. The discretion to make such on-the-spot decisions, which in effect are policy decisions, is going to be considerable, even for bureaucrats working within a dense tangle of rules designed to guide their behavior. It is simply a fact of political life that nonelected individuals, protected by civil service mechanisms and working for hierarchical (even authoritarian) bureaucracies, wield significant policymaking power in democratic polities. Given this, a key challenge for administrative theory is to account for this fact in the context of democratic values (Selden 1997, 13–26).