 Thirdly, there is the worry about “avoision.” By casting our categorical obligations in such agent-centered terms, one invites a kind of manipulation that is legalistic and Jesuitical, what Leo Katz dubs “avoision” (Katz 1996). Some think, for example, that one can transform a prohibited intention into a permissible predictive belief (and thus escape intention-focused forms of agent-relative duty) by the simple expedient of finding some other end with which to motivate the action in question.