On
Praise, Side Effects, and Folk Ascriptions of Intentionality
Thomas Nadelhoffer
In everyday discourse, we often draw a distinction between actions that are performed intentionally (e.g. opening your car door) and those that are performed unintentionally (e.g. shutting a car door on your finger). This distinction has interested philosophers working in a number of different areas. Indeed, intentional actions are not only the primary focus of those concerned with understanding and explaining human behavior, but they often occupy center stage in philosophical discussions of free will and moral and legal responsibility as well. And while most philosophers agree that the distinction between intentional and unintentional action plays an important role in our folk psychology, there is still wide-scale disagreement about the precise nature of this role. Until recently, there has been a lack of empirical data about the folk concept of intentional action and as a result the debate among philosophers has been mostly speculative. Lately, however, a number of philosophers and psychologists have begun making a concerted effort to fill in this empirical lacuna.
Joshua Knobe, for instance, has recently published data that suggest that moral considerations affect people’s judgments about whether a foreseen yet undesired side effect of an action was brought about intentionally (2003a). More specifically, he claims that people are “considerably more willing to say that a side effect was brought about intentionally when they regard that side effect as bad than when they regard it is as good” (2003a: 193). Interestingly, this result does not settle with another study of his involving folk ascriptions of intentionality in standard cases of action that do not involve side effects (2003b). In this second study, both positive and negative moral considerations affected people’s judgments about intentionality.
There are at least two ways to explain the
asymmetry of the results from Knobe’s experiments: First, it could be that people’s
judgments about the intentionality of non-side effect actions are sensitive to
positive moral considerations in a way that their judgments about the
intentionality of side-effect actions are not. In this case we would need to explain
why negative but not positive moral considerations affect people’s
judgments concerning the intentionality of side effect actions, while both
types of consideration affect their judgments about non-side effect actions. Second, we could look for another way of
explaining the asymmetry (e.g. F. Adams and A. Steadman, forthcoming). In this paper I take the latter route by
suggesting that Knobe gets disparate results because the two help vignettes of
his side effect experiments are not proper praiseworthy analogues to his
morally blameworthy harm vignettes.
After briefly setting the stage (§I) and discussing a few of
Knobe’s experiments (§II), I offer an alternative account of his
data that explains the asymmetry of his subjects’ judgments in the side
effect cases (§III). Then, I
support my explanation of Knobe’s research with data from an experiment
of my own (§IV), before concluding that people’s judgments about
actions – and the side effects of those actions – are affected by
both negative and positive moral considerations (§V).
There
is a long-standing debate in the philosophy of action concerning the nature and
proper role of the concept of intentional action. One of the central issues of this debate
is whether evaluative considerations do—or should—affect
folk ascriptions of intentional action.
While some scholars suggest that the concept of intentional action is
intimately bound up with evaluative considerations (e.g. Bratman 1987; Duff
1982; 1990; Harman 1976), others claim that because our concept of intentional
action is used primarily to predict and explain behavior,
evaluative consideration should not affect our ascriptions of intentional
action. Mele and Sverdlik (1996)
offer the most well-developed and forcefully argued defense of the view that
moral considerations should not act expansively on our ascriptions of
intentional action (see, also,
Another
central issue of the debate about the concept of intentional action is whether
a foreseen yet undesired side effect may be brought about intentionally. Consider, for instance, the following
example: In the landmark Smith
case of 1961, jurors in
The view that evaluative considerations do and should influence our intuitions concerning the intentionality of side effects has received support in the literature on intentional action. Michael Bratman, for instance, claims that a runner may intentionally wear down the soles of his heirloom shoes even though he doesn’t intend to do so (1987, p.123). As he says:
I conjectured that our inclination to extend what I do intentionally, in the light of my belief about my sneakers, is grounded in our interest in the ascription of responsibility. Our scheme for classifying actions as intentional is shaped in part by an interest in locating paradigm actions for which agents are to be held responsible. (1987, p.136)
And Gilbert Harman similarly claims that a sniper may intentionally alert his enemies when he shoots his target, even though he neither desires nor intends to alert them (1976, p.151). Thus, both Bratman and Harman believe that evaluative considerations do affect folk judgments concerning the intentionality of the side effects of an agent’s actions. In this respect, they would likely agree with R.A. Duff’s suggestion that:
Ascriptions of…intentional agency belong with ascriptions of responsibility and demands for justification. To say that A brings y about intentionally is to say that he is responsible for its occurrence and may have to justify his action under the description “bringing y about”…the criteria of intentional agency as to a given effect are also the criteria of responsibility for that effect” (1982, p. 4).
Given this view of the relationship between ascriptions of intentional action and ascriptions of moral responsibility, one can properly be said to intentionally bring about the foreseen, yet unintended and undesired, side effects of one’s actions.
Mele and Sverdlik, on the other hand, deny this claim and they offer an error theory that explains why the folk may be inclined to improperly allow evaluative considerations to affect their intuitions about whether the foreseen, yet unintended and undesired, side effects of an action are intentionally brought about. By their lights, while the folk may correctly assume that Bratman’s runner does not unintentionally (i.e. accidentally or unknowingly) wear down his shoes—or that Harman’s sniper does not unintentionally alert the enemies to his presence—they incorrectly assume that because the runner and sniper do not unintentionally bring about these side effects, it follows that they must have intentionally brought them about. Mele and Sverdlik claim that this assumption is false. Moreover, they show that there is a middle ground between unintentionally A-ing and intentionally A-ing, viz. non-intentionally A-ing (1996, p. 274):
Insofar as an agent who is A-ing is neither aiming at A-ing nor trying to A, either as an end or as a means to an end, she is not intentionally A-ing; insofar as an agent is A-ing knowingly and non-accidentally, she is not unintentionally A-ing; and actions that are neither intentional nor unintentional are nonintentional.
(p. 274)
Thus, according to Mele and Sverdlik, because Bratman’s runner and Harman’s sniper can properly be said to have brought about the respective side effects of their actions non-intentionally, we should not say that they brought these side effects about intentionally.[2]
Leaving aside for the moment the normative question of whether we should say that side effects are brought about intentionally, I want to consider whether we actually do say so. After all, as Mele has correctly pointed out, any adequate philosophical analyses of intentional action should be “anchored by common-sense judgments” about particular cases (Mele 2001:27). Thus, one way to test an analysis of intentional action would be to determine whether it agrees with our pretheoretical beliefs and intuitions. And the only way of knowing what the majority of non-specialists say about particular cases is to actually ask them. Having done so, if we find that an analysis of intentional action entirely fails to settle with folk intuitions, we will be in a good position to suggest that it “runs the risk of having nothing more than a philosophical fiction as its subject matter” (Mele 2001:27). Minimally, any philosopher who offers an account of intentional action that is not anchored by folk judgments would need to offer an error theory that explains how and why the folk are misapplying the concept. But we are getting ahead of ourselves. Before we can talk about how to interpret and explain data about folk intuitions, we should first look at Joshua Knobe’s laudable attempts to collect them.
II: Knobe’s Experiments
A:
Moral Considerations and Folk Ascriptions of Intentional Action
Working under the rubric of “experimental philosophy” and motivated by the reasonable assumption that psychological experiments can shed light on many of the crucial issues surrounding analyses of intentional action, Knobe conducted a series of surveys. One of the issues that he investigated is the aforementioned question of whether the concept of intentional action operates entirely independently of evaluative considerations. In answering this question, he used the four following scenarios—inspired by Mele (2001)—to conduct a few simple experiments:
(1A) Achievement/Skill: Jake desperately wants to win a rifle contest. He knows that he will only win the contest if he hits the bulls-eye. He raises the rifle, gets the bull’s-eye in the sights, a presses the trigger. Jake is an expert marksman. His hands are steady. The gun is aimed perfectly. The bullet lands directly on the bull’s-eye. Jake wins the contest.
(1B): Achievement/No-Skill: Jake desperately wants to win a rifle contest. He knows that he will only win the contest if he hits the bulls-eye. He raises the rifle, gets the bull’s-eye in the sights, a presses the trigger. But Jake isn’t very good at using his rifle. His hand slips on the barrel of the gun, and the shot goes wild. Nonetheless, the bullet lands directly on the bull’s-eye. Jake wins the contest.
(2A): Immoral/Skill: Jake desperately wants to have more money. He knows that he will inherit a lot of money when his aunt dies. One day, he sees his aunt walking by the window. Jake is an expert marksman. His hands are steady. The gun is aimed perfectly. The bullet hits her directly in the heart. She dies instantly.
(2B): Immoral/No Skill: Jake desperately wants to have more money. He knows that he will inherit a lot of money when his aunt dies. One day, he sees his aunt walking by the window. But Jake isn’t very good at using his rifle. His hand slips on the barrel of the gun, and the shot goes wild. Nonetheless, the bullet hits her directly in the heart. She dies instantly. (p. 313)
Each subject was presented with one of the four vignettes along with the following question: “Did Jake intentionally kill his aunt [hit the bull’s eye]?” (p.313). One of the primary goals of presenting the subjects with these vignettes and questions was to determine whether their judgments about these cases were affected by evaluative considerations. More specifically, Knobe wanted to ascertain whether the folk are more likely to say that Jake acted intentionally when he was attempting to perform the immoral behavior than they are when he was attempting to perform the achievement behavior. If so, this would speak against the truth of Mele and Sverdlik’s position understood as a position about what the majority of folk would say.
The results of Knobe’s experiments were both statistically significant and compelling. The subjects’ answers to the question about whether he acted intentionally were as follows:
Immoral: Achievement:
Skill: 95% 79%
No Skill: 76% 28%
From these results, Knobe draws the reasonable conclusion that evaluative considerations did affect the subjects’ ascriptions of intentional action—a result that Mele himself had explicitly predicted (Mele 2001). Indeed, when Mele originally discussed the four scenarios that Knobe’s vignettes are based on, he acknowledged that the folk may “treat morally significant and morally insignificant actions differently,” i.e. they might “have a lower threshold, for example, for the intentionality of ‘lucky’ actions deemed morally wrong than for the intentionality of equally lucky actions deemed morally neutral” (2001, p. 38).
As we saw earlier, Mele’s explanation of this tendency is that the folk are making “theoretical errors that taint their judgments about the cases” (Mele, 2001, p.41).[3] By his lights, because the folk erroneously assume that if an agent is morally responsible for having A-ed, then the agent must have A-ed intentionally, they falsely ascribe intentionality to the actions of an agent whenever the agent has done something morally blameworthy. And because it is “easy enough to show people that, upon consideration, they themselves would reject this assumption,” their tendency to allow evaluative considerations to affect ascriptions of intentionality is both mistaken and easily corrected (Mele, 2001, p.41). Thus, Mele suggests that we could disabuse the folk of their mistaken reliance on evaluative considerations by reminding them of cases of negligence and recklessness where the agent is still morally responsible. Once they are reminded of these types of cases, they will purportedly see that the assumption that blameworthy actions must be intentional is “false by their own lights rather than by the lights of an externally imposed theory” (Mele 2001, p.41).
To test Mele’s prediction, Knobe conducted yet another experiment. This time, he “causes subjects to believe that actions can be blameworthy even if they aren’t intentional” and tests to see whether they say that immoral/no-skill behavior is intentional (2003a, p.317). Once again, Knobe followed Mele’s suggested method of achieving this effect. He first exposed the subjects to the following vignette—taken directly from Mele (2001, p.41)—involving a person who does something that is clearly both unintentional and morally blameworthy:
Bob got rip-roaring drunk at a party after work. When the party ended, he stumbled to his car and started driving home. He was very drunk at the time—so drunk that he eventually lost control of his car, swerved into oncoming traffic, and killed a family of five.
Each subject was presented with two vignettes. On the first page was the vignette involving Bob’s drunken driving scenario, and on the second page was one of the vignettes from the previous study involving the no-skill conditions.
As was expected, 96% of the subjects said that Bob’s behavior was unintentional, yet when the subjects were asked to rate Bob’s blameworthiness on a scale from 0 (no blame) to 6 (a lot of blame), the mean rating was 5.3. So, obviously the subjects understood that people can—and presumably should—be held responsible for immoral yet unintentional actions. But the more important question is whether the subjects of this revised experiment answered the questions about the second vignettes differently than earlier subjects who had not been reminded of this possibility. And the results show that the answer to this question is “no.” Indeed, the subjects’ responses to the questions concerning the second vignettes showed the same asymmetry as before: 84% said the immoral behavior was intentional, whereas only 40% judged that the achievement behavior was intentional. Once again, Knobe’s results were statistically significant. And as Mele himself has subsequently admitted, the asymmetry of the folk judgments in this study spells “bad news” for his earlier hypothesis that if the folk do allow evaluative considerations to shape their ascriptions of intentional action, it is only because they overlook the fact that they can hold people morally responsible for unintentional actions in cases of negligence or recklessness (Mele, 2003, p.334).[4]
B: Moral Considerations and Side Effect
Cases
In another series of experiments, Knobe set out to determine whether folk intuitions about the intentionality of foreseeable yet undesired side effects are similarly influenced by moral considerations (Knobe, 2003a). The subjects of his first side effect experiment were presented with a vignette involving either a “harm condition” or a “help condition.” Those subjects who received the harm condition read the following vignette:
The vice-president of a company went to the chairman of the board and said, ‘We are thinking of starting a new program. It will help us increase profits, but it will also harm the environment.’ The chairman of the board answered, ‘I don’t care at all about harming the environment. I just want to make as much profit as I can. Let’s start the new program’. They started the new program. Sure enough, the environment was harmed. (2003a: 191)
The subjects were then asked to judge how much blame the chairman deserved for harming the environment (on a scale from 0 to 6) and to say whether they thought the chairman harmed the environment intentionally. 82% of the subjects claimed that the chairman harmed the environment intentionally.
Subjects in the help condition, on the other hand, read the same scenario except that the word “harm” was replaced by the word “help.” The subjects were then asked to judge how much praise the chairman deserved for helping the environment (on a scale from 0 to 6) and to say whether they thought the chairman helped the environment intentionally. Only 23% of the subjects claimed that the chairman intentionally helped the environment (2003a: 192).
In another side-effect experiment, Knobe got similar results. This time the subjects received one of the following two vignettes:
Harm Condition:
A lieutenant was talking with a sergeant. The lieutenant gave the order: ‘Send your squad to the top of Thompson Hill.’ The sergeant said: ‘But if I send my squad to the top of Thompson Hill, we’ll be moving the men into the enemy’s line of fire. Some of them will surely be killed!’ The lieutenant answered: ‘Look, I know that they’ll be in the line of fire, and I know that some of them will be killed. But I don’t care at all about what happens to our soldiers. All I care about is taking control of Thompson Hill’. The squad was sent to the top of Thompson Hill. As expected, the soldiers were moved into the enemy’s line of fire, and some of them were killed.
Help condition:
A lieutenant was talking with a sergeant. The lieutenant gave the order: ‘Send your squad to the top of Thompson Hill.’ The sergeant said: ‘But if I send my squad to the top of Thompson Hill, we’ll be taking them out of the enemy’s line of fire. They’ll be rescued!’ The lieutenant answered: ‘Look, I know that we’ll be taking them out of the line of fire, and I know that some of them would have been killed otherwise. But I don’t care at all about what happens to our soldiers. All I care about is taking control of Thompson Hill’. The squad was sent to the top of Thompson Hill. As expected, the soldiers were moved into the enemy’s line of fire, and some of them were saved. (2003a: 192)
Once again, the harm and the help conditions yielded drastically different responses: 77% of the subjects who read the harm condition said the agent intentionally brought about the negative side effect, whereas only 30% of the subjects who read the help condition said the agent brought about the positive side effect intentionally (2003a: 192). When Knobe combined the praise and blame ratings from the two experiments, he got the following results: Whereas the subjects who were given the harm condition said the agent deserved a lot of blame (M=4.8), the subjects who were given the help condition said that the agent deserved virtually no praise (M=1.4). Moreover, these results were correlated with their judgments about whether or not the side effect was brought about intentionally (2003a: 193). Thus, Knobe claims that:
There seems to be an asymmetry whereby people are considerably more willing to blame the agent for bad side effects than to praise the agent for good side effects. And this asymmetry in people’s assignment of praise and blame may be at the root of the corresponding asymmetry in people’s application of the concept intentionally: namely, that they seem considerably more willing to say that a side effect was brought about intentionally when they regard that side effect as bad than when they regard it as good. (2003a, p.193)
On the surface, Knobe’s conclusion appears to be well supported by his data, but I am now going to show that we have good reason to doubt whether this is actually the case.
III: An
Alternative Explanation
Because Knobe’s harm conditions elicited significantly different results than the help conditions, he concludes that the subjects’ ascriptions of intentionality were affected by the moral badness of the side effects of the former but not the moral goodness of the side effects of the latter. Moreover, he claims that whereas bad side effects appear to act expansively on the subjects’ ascriptions of blame, good side effects do not have similar effects on their ascriptions of praise. It is my contention that there is an alternative way of explaining the asymmetry of Knobe’s data. On my view – which at least in this one respect is similar to the one offered by Adams and Steadman (forthcoming) – Knobe gets disparate results because his praiseworthy help conditions are not proper analogues for his blameworthy harm conditions.
In order to see why this is the case, we should first look at Knobe’s harm conditions. For instance, when we read that the CEO doesn’t care that his plans will harm the environment, it is natural – and seemingly justified – for us to form a negative evaluation of the CEO. Similarly, when we read that the lieutenant in the harm condition does not care about putting his soldiers in the line of fire we understandably form a negative evaluation of the lieutenant. In both cases, because the two respective agents do not care about something that it is clear that they should care about we view them in an unfavorable light. This negative evaluation presumably explains subjects’ willingness to a) blame the CEO and the lieutenant in the harm conditions, and b) to say that the negative side effects of their respective actions were brought about intentionally.
Once we take a closer look at Knobe’s help conditions, however, we quickly find that the respective agents are not genuinely praiseworthy, as they would need to be in order for the help conditions to be isomorphic with the harm conditions. As Adams and Steadman correctly point out, “the language of the harm conditions seems natural (if uncaring), but the language in the help condition seems highly strained” (forthcoming). For instance, when we read that the CEO does not care that his plans will help the environment, we are not inclined to view his lack of concern favorably. After all, even the greediest corporate executive would presumably be pleased to find out that a business plan will not only yield a huge profit, but that it will also help the environment. So, the natural reaction – i.e. the reaction we would expect from such a CEO – would be, “Great! You mean to tell me that not only am I going to make large sums of money, but I will also be helping the environment as well? I couldn’t have planned this any better! This should keep the EPA off our backs for a while!” And the same thing can be said in the case of the lieutenant who curiously – and seemingly callously – doesn’t care that his soldiers will be removed from the line of fire. Once again, we expect a very different response. Rather than not caring at all about the welfare of his soldiers, we expect him to say something like, “Great! You mean that not only will I take Thompson Hill, but in doing so I will actually be saving my soldiers’ lives? Things couldn’t have turned out any better!”
In both of these cases it is precisely because we find the agent’s lack of concern very puzzling and highly inappropriate that we form negative evaluations of them. In this respect the harm conditions and the help conditions are quite similar. Indeed, in all four cases we do not form good opinions of the respective agents because each of them does not care about something that we think they should care about. By my lights, this not only explains why the subjects who received the harm conditions did judge that the agents deserved to be blamed for bringing about bad side effects, but it also explains why the subjects who received the help conditions did not judge that the agents deserved to be praised for bringing about good side effects.
Thus, Knobe’s conclusion – viz., that people’s judgments about the intentionality of side effects are affected by negative but not positive moral considerations – fails to follow from his data. On my view, the results of his side effect experiments show that insofar as subjects judge that an agent is blameworthy, they are more inclined to say that any negative side effects brought about by the agent are intentional and any positive side effects brought about by the agent are not intentional. Presumably this is because if the subjects who read one of the help conditions said that the side effects were brought about intentionally, they would have felt compelled to say that the agent deserved praise for intentionally bringing them about – something they were loathe to do insofar as they viewed the agents in the help conditions in a very negative light owing to their blatant lack of concern. But to the extent that even Knobe’s help conditions involve morally blameworthy agents, his data do not rule out the possibility that if people were presented with a morally praiseworthy agent who brought about positive side effects, they would be inclined to judge that the agent brought about the side effects of her action intentionally.
IV: Praise and Side Effects: A New Experiment
To see whether praise could affect people’s judgments about the intentionality of the side effects of an agent’s actions I conducted a simple experiment. The subjects were 40 undergraduates. Each received the following vignette:
Imagine that Steve and Jason are two friends who are competing against one another in an essay competition. Jason decides to help Steve edit his essay. Ellen, a mutual friend, says, “Don’t you realize that if you help Steve, you will decrease your own chances of winning the competition?” Jason responds, “I know that helping Steve decreases my chances of winning, but I don’t care at all about that. I just want to help my friend!” Sure enough, Steve wins the competition because of Jason’s help.
Then each of the subjects received the following two questions: First, did Jason intentionally decrease his own chances of winning the competition by helping Steve?
Second, how much praise does Jason deserve on a scale from 0 to 6 – 0 being no praise and 6 being a lot of praise – for decreasing his chances of winning in order to help his friend? The results were as follows: 55% of the subjects judged that Jason intentionally decreased his chances of winning. Moreover, the average praise rating for those who said that he intentionally decreased his chances of winning intentionally was 4.0, whereas the average praise rating for those who said that he did not intentionally decrease his chances was only 2.5. Thus, there is a positive correlation between how much praise subjects attributed to Jason and whether they judged that the side effect was brought about intentionally.
When we compare the results of my side effect experiment with Knobe’s data we get the following results: whereas 55% of my subjects judged that Jason brought about the side effect intentionally and they gave Jason a total praise rating of M=3.3, only 26.5% of the subject in Knobe’s CEO and lieutenant cases judged that the side effects were brought about intentionally and they gave the respective agents an average praise rating of M=1.4. I suggest that the best explanation of the asymmetry between the results of my experiment and Knobe’s two experiments is that in my help vignette Jason’s lack of concern is itself morally praiseworthy. So, when my subjects read that Jason cares more about helping his friend than about winning the competition – an admirable and noble lack of concern – they were presumably inclined to view him in a very favorable light. This explains why the subjects in my experiment were much more likely to judge that Jason deserved praise and thus that the side effects of his actions were brought about intentionally.
Given that I have successfully shown that praise acts expansively on people’s judgments concerning whether a side effect was brought about intentionally and provided that Knobe has shown a) that both blame and praise affect people’s ascriptions of intentionality in standard non-side effect cases (2003b; see also AUTHOR, forthcoming), and b) that blame affects people’s ascriptions of intentionality in side effect cases (2003a), we are now in a better position to conclude that both positive and negative moral considerations affect people’s application of the concept intentional.[5] Of course, before any definitive conclusions about folk ascriptions of intentional action can be reached, more research must be done. Minimally, I hope this paper serves as another small stepping-stone in that direction.[6]
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[1] The decision in this case was based on what has come to be known as the “objective standard.” The jurors were instructed to find Smith guilty of capital murder so long as a “reasonable person” could have foreseen the death—or grievous bodily harm—of the police officer, even if Smith didn’t actually foresee the officer’s death. Moreover, the judge’s instruction to the jury suggested that if a reasonable person could have foreseen the death, then Smith intended the death. Not surprisingly, the jury found Smith guilty of capital murder—a verdict that prompted England to pass the Criminal Justice Act of 1967 in an attempt to prevent similar verdicts in the future. According to this Act, “a court or jury, in determining whether a person has committed an offense, (a) shall not be bound by law to infer that he intended or foresaw a result of his actions by reason only of its being a natural and probable consequence of those actions; but (b) shall decide whether he did intend or foresee that result by reference to all the evidence, drawing such inferences from the evidence as appear proper in the circumstances.” Thus, a “subjective standard” replaced the aforementioned objective standard in English law. For detailed discussions of this case, see, e.g. Finnis (1991); Gorr (1996); Hart (1968); Kenny (1968); Lyons (1976), Oberdeik (1972).
[2] For a similar discussion of non-intentional action—i.e. action that is neither intentional nor unintentional—see Duff (1990: 77-9) and Mele & Moser (1994).
[3] See, also Mele & Sverdlik, 1996.
[4] Although it is possible that the only reason why the subjects judged that Bob was morally responsible was the fact that they were relying on some tracing principle to attribute blame to Bob because some action that led up to the accident—for example, his having decided to get drunk in the first place—was performed intentionally. In this case, because he did have control over his drunken state, he was judged to be responsible for the unintentional actions that occurred a result of his being in this state.
[5] Whether this reveals that the folk concept of intentional action is sensitive to moral considerations (Knobe 2003a; 2003b; forthcoming) or that pragmatic issues arising from conversational implicature affect folk ascriptions of intentional action (Adams and Steadman, forthcoming) is an open debate. My goal is simply to show that by using a morally praiseworthy help condition we can minimize the asymmetrical results of Knobe’s side effect experiments.
[6] I would like to thank Al Mele for helpful comments on an earlier draft of this paper.