One obtains Bell's inequalities if one posits a hypothetical joint probability distribution, or measure, whose marginals yield the probabilities produced by the spin measurements in question. The existence of a joint measure is in turn equivalent to a certain causality condition known as "screening off". We show that if one assumes, more generally, a joint quantal measure, or "decoherence functional", one obtains instead an analogous inequality weaker by a factor of √ 2. The proof of this "Tsirel'son inequality" is geometrical and rests on the possibility of associating a Hilbert space to any strongly positive quantal measure. These results lead both to a question: "Does a joint measure follow from some quantal analog of 'screening off' ?", and to the observation that non-contextual hidden variables are viable in histories-based quantum mechanics, even if they are excluded classically.