E&A 111/4 96
On Replaceability
Peter Singer has shown how the they ma ke possible the exis principle of utility, which enjoins us tence of intrinsically valuable (roughly) to maximize to balance of experiences like pleasure. It nonmoral good over nonmoral evil, is as if sentient beings are justifies 'humane' treatment of ani receptacles of something valua mals. 1 An excellent case against fac ble and it does not matter if a tory farming, blood sports, and cur receptacle gets broken, so long rent methods of an imal laboratory as there is another receptacle experimentation has been made on to which the contents can be utilitarian grounds. However, must a transferred without any getting utilitarian be opposed to all exploita spilt. 3 tion of animals' lives for human pleas u re or profit? Not according to the While it IS clear that captive ani 'replacement argument,' which tells us mals would be vastly better off under that: such an arrangement than they are 1. We ought to maximize util now, is it really the case that 'hu ity (i.e., to maximize the mane' farms and labs are morally jus balance of nonmoral good tifiable? Moreover, what a re the over nonmoral evil). implications of this argument for the 2. Utility would be maximized treatment of humans?4 How can one if one were to use an ani determine whether a normative ethical mal and kill it (for food or theory has gone too fa r? Some brief research or anything else) remarks about the nature of ethical provided that the following justification must be made before these conditions are met: questions can be answered. (a)· the life of the animal is on balance a Iife worth The major metaethical theories have living, different implications about the precise (b) the animal otherwise kind of justification normative ethical would have no life at all claims can have. According to natu (would not exist), ralistic and nonnaturalistic metaethical (c) the sufferi ng of the theories, ethical claims are factual animal and those close to assertions which can in principle be it as a result of such shown true or false. (Naturalism use and disposal is elimi implies that ethical language users nated or minimized, and believe there are natural ethical prop (d) the· animal will be erty instances; nonnaturalism implies replaced, at or after that ethical language users believe death, by another animal there are nonnatural ethical property for whom conditions (a), instances.) Noncognitivist metaethical (b), (c), and (d) hold. theories, on the· other hand, imply 3. Therefore, we ought to use that ethical claims are not (at all or and kill animals provided merely, depending on the type of that conditions (a) (d) noncognitivism) factual and thus are are met. 2 neither true nor false. Some of these major theories are much more plausible Classical utilita rian ism is committed than others, of course, but it would to this argument. As Singer says, it go beyond the scope of this paper to . . rega rds sentient beings discuss thei r respective merits. 5 as valuable only in so far as Suffice it to say that it is fa r from 97 E&A III/4 obvious that ethical claims can be qualified ethical 'intuitions' are the given a straightforward justification. touchstones of normative ethical theo ries. Without them, such theories This does not mean, however, that could neither be formulated nor it is doubtful that they can be justi tested. The qualified attitude method fied at all. Ethical claims can be does, however, have one difficulty. rationally accepted or rejected even if It is theoretically possible that indi noncognitivism is true. Ethical claims viduals with equally qualified ethical are. standardly discounted if they fail attitudes will disagree. Were this to to be clearly thought out, fully occur, ethical argumentation must informed, and impartial. (It is crucial cease. Nevertheless, I would agree to note that empathy [vividly imagin with W. K. FrankenaFran kena that such a ing oneself in another's position] is disag reement is no more than a theo necessary for a fully informed judg retical possibility. 7 It is extraordi ment about matters that concern sen narily difficult to come up with an tient beings. It is a way of gaining ethical disagreement in which both highly relevant information about the sides a re equally qual ified. Fran ke effects of actions on such beings. na's assertion will, however, .be tested One must of course empathize equally later in this paper. With this back vividly with all sentient beings which ground in mind, let us now return to an action significantly concerns if one the replacement a rgument and the is to be impartial.) All the major implications by which it will be tested. metaethical theories are compatible with these facts, as of cou rse they We will begin by considering a must be in order to have a chance of very serious implication of the being correct. Even if ethical claims replacement argument: if animals are are not assertions about the instantia replaceable, so are human beings with tion of natural or nonnatural proper comparable characteristics in like cir ties in acts, entities, or states of cumstances. I will not here repeat affai rs, they a re made about acts, the extensive argumentation by phi entities, or states of affairs. If one's losophers for the conclusion that thin king is muddled, or if one is preferential treatment for humans who ignorant of relevant facts, or if one is differ in no relevant respects from biased and thus selectively aware of animals cannot be justified and is in only some of the relevant facts, one's fact speciesist (hence not impartial). claim is unjustified: one does not Many attempts have been made to jus know what one's claim is about. tify such preferential treatment, but Thus, even if there are no ethical in my judgment none has succeeded. 8 facts, one's ethical judgments can be If conditions (a) - (d) can be satis justified if they are shown to be qual fied by morons, stocking and using ified by being clear, fully informed, them for food or experimentation is no and impartial.' This also applies to more or less reprehensible than doing sets of ethical claims. They too must so with animals. Thus, if the ethical be clear, coherent, informed, and belief "Morons should not be raised, impartial. If an ethical claim or a set made into stew or used as lab sub of ethical claims is not qualified in jects, then replaced, but it is permis these respects, it is discounted. sible to treat animals in this way so long as utility is maximized" is shown This method of justification,' which to be unjustified (unqualified), one is I will follow R. B. Brandt in calling left to discard half of this conjunc 'the qualified attitude method, '6 gives tion. us a way of rationally arguing about ethical claims. It also explains why Most individuals facing thisth is choice E&A 111/4 98 would revise their beliefs about the noted that those who, unlike Singer, treatment of animals rather than opt do not accept the replaceability of for moron stocking. I believe such a defective humans must reject the choice to be vey reasonable. If one replacement argument. fully considers the moron stocking scena rio ina clea r, empathetic, The next objection is this. The impartial way, I find it hard to see replacement argument as it stands has how one can accept it. Unfortu an implication which would horrify nately, some philosophers do not find Singer. It applies to any sentient it so hard to see and appear to be creatu re for whom conditions (a) willing to accept such a scenario. (d) are satisfied. It follows that even Peter Singer has (courageously or normal humans are replaceable, so outrageously, depending . on one's long as utility is maximized. As viewpoint) taken this position. He Singer says, "Situations in which the suggests that if the replacement argu argument would apply to humans might ment cannot be defeated "it is our not be common, but they could attitudes to mentally defective human occur."12 Even those who are willing beings that are in need of reconsider'" to accept the raising, eating, etc., ation:" 9 and replacement of defective humans, This involves holding that bal k at the notion that normal nonde mental defectives do not have a fective humans are in the same boat. right to life, and therefore One who is disturbed by this implica might be killed for food--if we tion must eiher reject the replacement . should develop a taste for argument wholly, i.e., for animals and human flesh--or (and this defective humans as well as normal really might appeal to some humans, or opt to restrict the people) for the purpose of sci replacement argument in such a way entific experimentation. 10 that it cannot apply to normal Singer seems in no way horrified by humans. Since classical utilitarianism this prospect. Elsewhere he says that leads to the replacement argument, even nondefective human infants "are either choice implies its rejection as as replaceable as merely conscious well. an imals. "11 What can one say to a philosopher like Singer who is willing Singer chooses to replace classical to make his ethical bel iefs consistent utilitarianism with another version of and impartial by applying the replace utilitarianism which he believes allows ability principle in this nonspeciesist him to restrict the replacement argu way? ment. He first rejects a tempting nonclassical-utilitarianism solution to One could try to argue that Sing the problem, 'the prior existence er's position, though apparently view,' according to which the princi impartial, is not sufficiently clear or ple of utility applies only to beings well informed. Such a response to already in existence. 13 Although on Singer would be very difficult to make such a view utility could obviously out and I am loathe to try it here. I never be maximized by replacement of prefer to develop another objection to sentient beings, it is impossible to the replacement argument which I do avoid the conclusion that the solution not think Singer can successfully is arbitrary as well as contrary to the cou nter, an objection wh ich wi II have spirit of utilitarianism. To say that the indirect result of rejecting the the principle of utility does not even replacement argument for defective apply to those unborn is to open a humans. Before proceeding with this hornets' nest of difficulties. The dif new objection, however, let it be ficulty which troubles Singer is the 99 E&A 111/4 implication that it would not be wrong and what suffering others undergo on knowingly to conceive a child whose its account minimized, and will be physical defects would condemn it to a replace by another bei ng who wou Id brief life of wretched suffering. 14 live and die under the same condi would put the criticism more gener tions, no preference utilitarian objec ally. A view which implies that tion would, believes Singer, be made. future generations simply do not count What beings, according to Singer, can in their own right (i.e., that we have pleasant lives yet not prefer to should consider them only insofar as live? Beings who have no concept of they would affect those now existing) self: 'merely conscious' bei ngs. clashes with our qualified ethical intu Those who can have a preference for itions. Classical utilitarianism, which continued life must be self-conscious. bids us maximize the balance of total Indeed, Singer apparently takes self utility over disutility, quite properly consciousness to be sufficient as well does extend the principle of utility to as necessary for such a preference. those who do not yet exist. Instead He d raws the followi ng impl ication for of accepting the prior ex istence view, preference utilitarianism: Singer chooses to adopt a utilitarian Self-conscious beings therefore ism which, like classical· utilitarianism, are not mere receptacles for does not restrict the princple of util containing a certain quantity of ity to those who already exist. This pleasu re, and a re not replace view is 'preference utilitarianism.' able nonself-conscious According to it, utility is directly beings are replaceable. 16 assigned to the preferences of beings The replacement argument is accord affected by actions, not merely to ingly restricted to beings who are not their states of consciousness. Killing self-con sciou s, a class wh ich excl udes a being which has a preference to normal humans. In this way Si nger continue living creates, other things believes he has avoided an unaccepta being equal, more disutility than kill ble consequence of the orginal ing a being which has no such pref replacement argument. erence. However, serious problems afflict It follows, Singer believes, that on this attempt simultaneously to save preference utilitarianism a living being and restrict the replacement a rgu who prefers to live will be favored ment. Fi rst, let us for the moment over its merely potential replacement, not question the assumption that which can have no preference for life self-conscious beings are irreplaceable since it does not yet exist. 1s This is on preference utilitarianism. Now let so even if the being is painlessly us ask if there are any conscious killed all unsuspecting in its sleep: beings who are 'merely'r conscious, even in that case, a preference has with no concept whatever of self. been extinguished. The total amount Certainly many severely defective of happiness or satisfaction, etc., humans show signs of self-conscious including that which a replacement ness. They perform actions, have would have, is still taken into goals, show no tendency to confuse account: it is the existing being's themselves with table-legs, etc. Mon preference to live which tips the keys, apes, dogs, cats, horses, pigs, scales in its favor. However, if an sheep, etc., likewise exhibit behavior existing being has no preference for which would be hard to explain with continued life, its demise will not cre out the postu lation of self-conscious <;It" extra disutility, If it WQuid not ness, Even chickens seem to be, otherwIse have been alive, has lived a however dimly,. aware of themselves. pleasant life, has had its suffering They too have no tendency to confuse E&A 111/4 100 themselves with the rest of the world. a very soph isticated conception of Furthermore, even the infant members itself. It must conceive of itself as "a of these species exhibit such signs. distinct entity with a possible futu re Though Singer is predictably not at existence. "18 If it has a more impov all distu rbed by the excl usion of adu It erished conception of itself it "can monkeys, apes, and other 'higher' not," as he puts it, "have a prefer animals from the class to which the ence about its own futu re replacement argument applies, he con existence."19 But to demand this tinues to think that many sentient degree of sophistication is surely beings will not be excluded (e.g., unwarranted. I suspect that this normal as well as defective human demand has its origin in Singer's infants, probably chickens,· and cer uncritical acceptance of a faulty infer tainly animals lower on· the evolution ence by Michael Tooley, a philosopher ary scale than chickens). 17 It is whose views on self-consciousness highly doubtful that all these beings Singer uses to support preference can be made out to lack self-con utilitarianism. 20 Tooley argues that sciousness of any kind. Clams and 1. 1. One can have a right to oysters may not be self-conscious, but life only if one is capable the replacement argument would lose of desiring life. most of its point if it were restricted 2. 2. One can be capable of to them. (Although tasty, they ma ke desiring life only if one has poor experimental subjects. ) a concept of life. 3. 3. The kind of life is question Perhaps Singer would reply that is being a continuing sub although babies and chickens cou ld be ject of experiences and said to be self-conscious, they are not other mental states. self-conscious enough to have a pref 4. 4. Therefore one can have a erence for continued life. (He would right to life only if one has then have to take self-consciousness a concept of bei ng a con as such to be merely necessary for tinuing subject of experi the preference for continued life.) ences and other mental But on what grounds are we to states. 21 declare that a baby or chicken has no The inference to (3), as W. S. Pluhar preference for continued life? What is has pointed out,22 commits the inten 'life' but a series of experiences and tional fallacy. One can desire life what is a preference for continued life without thinking of it in these highly but the desi re for more experiences? sophisticated terms just as one can Is not the seeking of pleasure and the desire to meet Archibald Cox without avoidance of pain, clea rly exhibited thinking of him as a Harvard law pro by the beings in question, sufficient fessor. There is therefore no reason evidence for the desire to continue to deny that sentient beings who living? If Singer wishes to claim that behave. as if they prefer to live do such behavior is instinctive only he prefer to live. The replacement would find himself at odds with many argument as restricted by Singer current theorists about animal behav appears to be vastly more restricted ior. Why insist that a baby or kitten than he believes and thus looses its who seeks warmth, food, and compan point .. ionship, cannot prefer to continue liv ing? Now, however, an even·more seri ous objection can be raised. The The answer is that Singer appears first objection to the preference utilit to be thinking that an animal or arian version of the replacement argu human who prefers to live must have ment, just spelled out above, did not 101 E&A I II/4 challenge the assumption that prefer utilitarianism with a view he rejects: ence utilitarianism would imply that the prior existence view. The reader self-conscious beings are irreplace will recall that in seeking to render able. We saw that the argument, the replacement argument inapplicable given this assumption, appl ies to very to normal, self-conscious humans he few sentient creatu res. A much more rejected the prior existence view serious problem arises for Singer (which does not assign utility to the when we examine this assumption. It states of mind, etc., of nonexistent tu rns out to be simply false that beings) in favor of preference utilita preference utilitarianism implies the rianism. 24 The prior existence view irreplaceability of self-conscious was rejected because it did not imply bei ngs. the wrongness of deliberately conceiv ing an incurably and painfully The problem is this. The replace deformed child who would die before· ment for the painlessly, fearlessly his second bi rthday. Suppose that dispatched self-conscious being also the child's mind is unimpaired. We has a preference for continued life. would then think it probable that he It is not different in th is respect from would develop a preference for nonex its predecessor. If the new prefer istence. Yet such a preference would ence and the old preference a re equal simply not count if Singer were to try in strength, they must be assigned to escape the disastrous implication in the same utility; therefore, preference the way I have suggested. Thus, his utilitarianism does not favor the view would be subject to the same replacee over the replacer rega rdless objection as the view he has rejected . of whether the former is self-con scious. If Singer were to reply that he would take the misery of the child Perhaps Singer would try to avoid into account and thus condemn its this (for his purposes, disastrous) deliberate conception, then he ought implication by arguing that a being to take its potential preferences into which does not yet exist (the. repla account as well. Its misery is also cer) cannot have any preferences. merely potential, after all. And in All such preferences, he might say, that case the preferences which any are potential only. There is evidence nonexistent being will have ought to that Singer would reply in that way. be taken into account. Thus, the He argues that . normal infants are original objection reemerges: prefer replaceable because they as yet have ence utilitarianism does not favor the no preference to continue living: self-conscious replacee over its self Potential self-consciousness is conscious replacer if we can expect not enough, for a potentially the replacer's preference to live to be self-conscious being has never at least as strong as the replacee's.25 desired to go on living. 23 I see no way in which Singer can Similarly, an as yet nonexistent being consistentlyconsistently avoid thisthis objection. has no actual preference for continued life. Thus, Singer could reply, pref We have seen that when the erence utilitarianism does indeed favor assumption that preference utilitarian the existent being with a preference ism implies the irreplaceability of to continue living ovel' any nonexis self-conscious beings is not ques tent replacement. tioned, the replacement argument applies to hardly any beings at all. However, this line of reply is When the assumption is questioned, actually closed to Singer, because it the argument applies to all sentient presupposes an amalgam of preference beings. Both alternatives are E&A II1/4 102 unacceptable to Singer. Therefore, I believe one can, by appealing to his attempt to restrict the replacement a pragmatic version of the argument argument to nonself-conscious animals from moral consistency. The principle and humans has thoroughly defeated of utility is itself arrived at by appeal itself. to ethical intuitions. Various versions of utilitarianism are likewise accepted In the absence of any other plausi or rejected by utilitarians by such ble new utilitarian version of the appeals. For example, Singer rejects replacement argument which would the prior existence view because it avoid the above entanglements, one is has an implication "we would think.. entitled to conclude that the replace .wrong;"27 similarly, he raises doubts ment argument does indeed apply even about classical utilitarianism on the to normal humans. Therefore either grounds that "all this is, again, very the replacement argument, and utilita much at odds with our ordinary moral rianism, must be rejected, or the convictions. "28 Moreover, utilitarians implication must be accepted. It is have devoted a good deal of effort to now time to press the argument from the task of showing some version of moral consistency on proponents of utilitarianism consistent with standard the replacement argument. Anyone intuitions about lying, promise keep who, on careful, clear, impartial ing, and punishment of the innocent. reflection, believes that it is wrong to My point here is not merely to charge create, 'humanely' use, then replace any utilitarians who accept the impli normal humans, will have to reject the cations of the replacement argument replacement argument for other sen with inconsistency. I believe they are tient beings as well. The principle of entirely right to appeal to ethical utility must then be rejected as the intuitions at these crucial points. only·' basic moral principle. They are also right to insist that the intuitions appealed to be qualified. Suppose, on the other hand, that As mentioned earlier, without such some utilitarians decide not to agree appeals ethical theories can neither be with Singer's claim that formulated nor tested. These reflec If we think of a living creature tions do however suggest that a util as a self-conscious i ndivid ual, itarian who relies on clear, informed, leading its own life and with a impartial ethical intuitions in trying to desire to go on living, the formulate his theory but who rejects replaceability argument holds them when they run counter to his Iittle appeal. 26 theory is guilty of a pragmatic, if not It is enti rely possible that some wou Id formal, inconsistency. (If a utilita prefer to accept the replaceability of rian can show that the ethical intui normal humans rather that to reject tion that it is wrong to create, use, the replacement argument and utilita and replace a normal human being is rianism. They would probably argue not qualified in the above respects, that they a re not impressed by an he is not guilty of this charge. How appeal to ethical intuitions, that just ever, no such thing has been shown.) as they do not shy from the thesis that defective humans a re replaceable, If then the principle of utility is, they are willing to accept the replace after careful moral reflection, not ability of humans like themselves. taken to be the only basic moral prin "Why," they might say, "should we ciple, we must look for an additional abandon utilitarianism rather than principle (and thus to a deontological abandon an ethical intuition?" Can theory) which do.es square with quali one ,'easonably counter such a draco fied ethical intuitions concerning nian moral consistency? replaceability. To formulate and then 103 E&A III/4 defend such a principle is no easy ble, such use seems wrong I even if task. I will here confine myself to precautions have been taken to make some brief remarks on this subject. the being as happy as possible. Tom Regan has been trying to formu However, I do believe Regan errs in late such a principle in his recent stipulating that it is treatment of an writings, and the results are very inherently valuable being as a means suggestive. Briefly, he a rgues that only that is improper. Under the if sentient (or non sentient) beings conditions of the replacement argu have basic rights, they have those ment, sentient bei ngs a re not treated rights because they are inherently as means only: their well-being is valuable. He spells out the "most taken into account in the attempt to noteworthy features" of inherent value maximize the balance of inherent non as follows: moral value over disvalue. (Current 1. 1. If any given being (x) has treatment of animals, by contrast, inherent value, then x's comes very close to treatment of them hav ing val ue of t his kin dis as means only.) On the other hand, logically independent of any it is clear that stocking, using, dis other being's happening to posing of, and replacing sentient cre take an interest in or oth atures, however benevolently this is erwise valuing x. done, is to treat them primarily as 2. 2. X's having inherent value means. Therefore I' would suggest makes it improper (a sign amending Regan's feature (2) as fol of disrespect) to treat x as lows: . though it had value only as 2. 2. X's having inherent value a means (i. e., only if and makes it improper (a sign only so long as it answers of disrespect) to treat x as another's needs, etc.). though it had val ue prima 3. 3. Because x's having inher rily as a means. ent value underlies the obligation to treat x with Much work remains to be done on respect, and since some the criterion of inherent value, as thing's being good-of-its Regan is the fi rst to say. 30 How kind is not a plausible ever, if the reasoning in the earlier basis on which to found part of my paper is correct, and the this obligation, x's being replacement argument must indeed be good-of-its-kind is logically rejected for humans and animals, the distinct from x's having formulation and testing of this or some inherent· value. 29 other principle as part of a deontolo gical theory is the next order of Regan's 'criterion of inherent val business. ue' does seem to captu re the convic tion that stocking, eating or experi menting on, and then replaci ng a Evelyn B. Pluhar Pluhar sentient creature with another just like it and with the same fate, is to Pennsylvania State University, University, treat it as instrumentally valuable. If Fayette Campus Campus the being is in fact inherently valua- E&A II 1/4 104
NOTES
Peter Singer, Animal Liberation Liberation 11 Singer, "Killing Humans and Killing (New York: Avon Books)' Books), 1975. 1975. Animals," op. cit., p. 153.
2 The statement of the second prem prem• 12 Singer, "Animals and the Value of ise of this argument is taken from from Life," op. cit., p. 250. Although he Ethics & Animals, 3 (1), March 1982, 1982, is thinking primarily of defective p. 2, with one alteration: condition humans here, the same applies to (c) has been added in order to meet those who are normal. the requirement that utility be maxim ized by animal exploitation. 13 Singer, "Killing Humans and Killing Animals," op. cit., pp. 148-150. 3 Peter Singer, "Killing Humans and and Killing Animals, " Inquiry, 22, nos. nos. 14 Ibid., p. 148. 1-2, Summer 1979, p. 149. See also also his essay, "Animals and the Value of of 1 5 Ibid., p. 152 . Life," in Tom Regan, ed., Matters of of Life and Death (New York: Random Random 16 Ibid. House), 1980, p. 249. 249. 17 Ibid., p. 153. 4 I am followi ng the conven ient p rac tice of abbreviating 'human animal' as 18 Singer, "Animals and the Value of 'human' and 'nonhuman animal' as 'an Life," op. cit., p. 238. imal.' This terminology is not meant to beg any questions about the moral 19 Ibid. status of animals. 20 Ibid., pp. 239-240, and "Killing 5 For excellent discussion of the pros Humans and Killing Animals," op. and cons of important metaeth ical cit., p. 151. theories see R. B. Brandt, Ethical Theory (Englewood Cliffs: Prentice 21 Michael Tooley,Tooley, "Abortion and Hall), 1959, W. K. Frankena, Ethics Infanticide," in M. Cohen, T. Nagel, (Englewood Cliffs: Prentice-Hall), and T. Scan Ion, eds., The Rights and 1973, and J. L. Mackie, Ethics (Lon Wrongs of Abortion (P ri nceton : don: Cox and Wyman Ltd.), 1977. P~inceton U. Press), 1974, pp. 60-62.
6 R. B. Brandt, op. cit., Chapter 22 Werner S. Pluhar, "Abortion and 10. Simple Consciousness,:" Journal of Philosophy, LXXIV (3), March 1977, 7 W. K. Frankena,Ethics, op. cit., p .. 162. p. "1. 23 See his "Killing Humans and Killing 8 See my "Must an Opponent of Ani Animals," op. cit., p. 153. mal Rights also be an Opponent of Human Rights?", Inquiry, 24, 1981, 24 See above, pp. 98-99. pp. 229-41. 25 Michael Lockwood makes this point 9 Singer, "Animals and the Value of of in his "Singer on Killing and the Life," op. cit., p. 251. 251. Preference for Life, " Inquiry, 22 (1-2), Summer 1979, p. 159, when he 10 Ibid., p. 245. argues that preference utilitarianism 105 E&A 111/4 cannot be used to decide the issue Defense of one Argument Concerning between a pregnant woman ... and the Animal Rights," Inquiry, 22 (1-2), child who would live only at the cost Summer 1979, p. 206. See also his .of her death. "The Nature and Possibility of an Envi ronmental Ethic, " Environmental 26 Singer, "Killing Humans and Killing Ethics, 3, Spring 1981, pp. 30-32. Animals," op. cit., p. 151. 3D I explore the problems facing this 2 7 Ibid., p . 148. criterion and the type of justification it can and cannot be given in my 28 Singer, "Animals and the .Value of "The Justification of an Environmental Life," op. cit., p. 249. Ethic," forthcoming in Environmental Ethics. 29 Tom Regan, "An Examination and