2008] The Minimum Core of Economic and Social Rights 163 legitimacy. A second compromise, furthered by Mark Tus hnet’s modeling of strong and weak judici al review, is to combine the strong version of the adjudicated minimum core with a weak ver sion of remedy.289 The “strength” of the rights may be measured in terms of the level of review employed by the court, and t he “strength” of the r emedy may be measured in terms of a mandatory, time-lined, or precise order, versus a declaratory, open-ended, or negotiated one, or one subject to legislative override.290 C. Unraveling Cores: The Challenge of Polycentricity In both the monitoring and adjudication contexts, the enumeration of the core as an expression of core obligations or ju sticiable complaints is ultimately unsatisfactory. Despite collecting a set of important institutional duties and challenges together, the project is prone to unravel. This is because the insurmountable problem for the notion of core obligations is that the particular forms of duties are intrinsically polycentric and cannot be subject to a definitive ranking; that is, the exercising of splitting each cluster into the constituent Hohfeldian elements, and assigning particular clusters as “core,” is ultimately bound to come undone.291 The challenge of polycentricity is not to deny the importance of understanding the many and varied duties that flow from the recognition of economic and social rights, and of working to delineate particular institutional obligations around them. 292 It is, however, inconsist ent with the project of demarcating the “core.” Some commentators have argued th at, in fact, duties to protect and duties to respect bear an inve rse relation to each other—that is, as the duties to respect rights expand, the duty to prot ect must narrow. Certainly, in Henry Shue’s typology, such a relationship is imagined, thus rendering the idea of “core obliga tions” inherently ambiguous. Shue has argued that t he duties expand or contract in relation to each other—for example, the (positive) dut y to protect what he te rms “subsistence” broadens as the (negative) duty to respect it narro ws, and vice versa. T hus, reliance on the state’s “core” duty to avoid depriving economic and social rights, which would resemble the classical liberal duty of r estraint of harm, would be insufficient in all but the most rights-r especting societies. Similarly, reliance on an alternative core duty to protect economic and so cial rights would create a vast law enforcement and police power, or at least inquir e more vigorously into the actions and omissions of institutions.293 The creation of multiple “core 289. Tushnet, Social Welfare Rights , supra note 13, at 1912 (suggesting, from comparative study, that the dynam ics come in several forms, th e most interesting being a combination of strong substantive right and w eak remedy). But see Sturm, supra note 283 (introducing ne gotiation and other measures which complicate “strength” and “weakness” classifications). 290. TUSHNET, supra note 287, at 1912. 291. See Jeremy Waldron, Introduction to THEORIES OF RIGHTS 1, 10-11 (Jeremy Waldron ed., 1984). 292. The term “polycentricity” was applie d to this context by Lon L. Fuller, The Forms and Limits of A djudication, 92 H ARV. L. REV. 353, 394-98 (1978), referring to a polycentric (or “m any centered”) problem as one unsuited to resolution by adjudication. Fuller derived the term from MICHAEL POLANYI, THE LOGIC OF LIBERTY (Liberty Fund 1998) (1951). 293. SHUE, supra note 78, at 60-61 (revising an earli er emphasis on negative duties by broadening the focus on institutions, instea d of si mple law-and-order contexts); see also THOMAS