A rubber stamp, as a political metaphor, is a person or institution with considerable de jure power but little de facto power — one that rarely or never disagrees with more powerful organizations. Historian Edward S. Ellis called this type of legislature a toy parliament. In a constitutional monarchy or parliamentary republic, heads of state are typically "rubber stamps" (or figureheads) to an elected parliament, even if they legally possess considerable reserve powers or disagree with the parliament's decisions.