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I. Introduction
Models of democracy are hardly separable from models of constitutionalism. The model of democracy that a person embraces may determine to a great extent the model of constitutionalism that she will adhere to. Thus, for example, if someone is persuaded by the virtues of direct democracy, it is unlikely that she would favor a model of constitutionalism that includes review by nonelected judges of the constitutionality of the content of legislation approved by the people through a referendum- although she would presumably admit the legitimacy of judicial review of the constitutionality of the procedural aspects of such a referendum. The same goes for those who advocate strong versions of deliberative democracy: they would be likely to accept judicial review of the constitutionality of laws regulating the democratic process, but not the control of the constitutionality of the substantive outcomes adopted through well-conducted, deliberativedemocratic procedures.1
Of course, the assertion that models of democracy have a profound impact on models of constitutionalism presupposes the adoption of an external point of view in relation to the latter2-that is, one that regards different accounts of constitutionalism as equally plausible, which is problematic for those of us who think that there are some very specific core values associated with the concept of constitutionalism. Having said this, if we assume for a moment such an external approach to constitutionalism, it becomes immediately apparent that there are, at the present time, competing accounts of both democracy and constitutionalism in Latin America. In the 1990s, there was widespread consensus throughout the region as to the virtues of liberal democracy and the model of constitutionalism prevalent in Western Europe, the United States, and other former British colonies. In recent years, however, some Latin American countries have diverged from that consensus and embraced different models of democracy, which have led them to adopt different models of constitutionalism. For example, Venezuela, Bolivia, and Ecuador have, over the last few years, adopted radical forms of democratic rule-multiethnic democracy in Bolivia and Ecuador,3 and the so-called Bolivarian democracy in Venezuela4-that have been shown to be incompatible with some core elements of the liberaldemocratic model of constitutionalism, such as judicial independence and full freedom of expression.
Given this scenario, and bringing back the internal point of view...