"Libertarianism: Bogus Anarchy", anarchist Peter Sabatini notes: Similarly, Bob Black argues that an anarcho-capitalist wants to "abolish the state to his own satisfaction by calling it something else". He states that they do not denounce what the state does, they just "object to who's doing it". Paul Birch argues that legal disputes involving several jurisdictions and different legal systems will be too complex and costly. He therefore argues that anarcho-capitalism is inherently unstable, and would evolve, entirely through the operation of free market forces, into either a single dominant private court with a natural monopoly of justice over the territory (a de facto state), a society of multiple city states, each with a territorial monopoly, or a 'pure anarchy' that would rapidly descend into chaos. Randall G. Holcombe argues that anarcho-capitalism turns justice into a commodity as private defense and court firms would favour those who pay more for their services. He argues that defense agencies could form cartels and oppress people without fear of competition. Philosopher Albert Meltzer argued that since anarcho-capitalism promotes the idea of private armies, it actually supports a "limited State". He contends that it "is only possible to conceive of Anarchism which is free, communistic and offering no economic necessity for repression of countering it". Libertarian Robert Nozick argues that a competitive legal system would evolve toward a monopoly government—even without violating individuals' rights in the process. In Anarchy, State, and Utopia, Nozick defends minarchism and argues that an anarcho-capitalist society would inevitably transform into a minarchist state through the eventual emergence of a monopolistic private defense and judicial agency that no longer faces competition. He argues that anarcho-capitalism results in an unstable system that would not endure in the real world. While anarcho-capitalists such as Roy Childs and Murray Rothbard have rejected Nozick's arguments, with Rothbard arguing that the process described by Nozick, with the dominant protection agency outlawing its competitors, in fact violates its own clients' rights, John Jefferson actually advocates Nozick's argument and states that such events would best operate in laissez-faire. Robert Ellickson presented a Hayekian case against anarcho-capitalism, calling it a "pipe-dream" and stating that anarcho-capitalists "by imagining a stable system of competing private associations, ignore both the inevitability of territorial monopolists in governance, and the importance of institutions to constrain those monopolists' abuses". Some libertarians argue that anarcho-capitalism would result in different standards of justice and law due to