According to A. John Simmons's anarchist scepticism, there is no duty to obey the law as things stand, as legal obligations have legitimacy only when voluntarily incurred by most or many citizens. However, an alternative, pluralist position is suggested by Simmons's sensitivity to the diversity of reasons and to the possibility of unresolved conflict. It shows that the grounds of legitimate authority are plural, and include distributive justice. Also, even voluntarily incurred obligations can be defeated by conflicting reasons, as when we are duty bound to an unjust regime.