 Simmons (1992) presents a still different synthesis. He sides with Waldron (1988) and against Tully (1980) and Sreenivasan (1995) in rejecting the workmanship model. He claims that the references to “making” in chapter five of the Two Treatises are not making in the right sense of the word for the workmanship model to be correct. Locke thinks we have property in our own persons even though we do not make or create ourselves. Simmons claims that while Locke did believe that God had rights as creator, human beings have a different limited right as trustees, not as makers. Simmons bases this in part on his reading of two distinct arguments he takes Locke to make: the first justifies property based on God’s will and basic human needs, the second based on “mixing” labor. According to the former argument, at least some property rights can be justified by showing that a scheme allowing appropriation of property without consent has beneficial consequences for the preservation of mankind. This argument is overdetermined, according to Simmons, in that it can be interpreted either theologically or as a simple rule-consequentialist argument. With respect to the latter argument, Simmons takes labor not to be a substance that is literally “mixed” but rather as a purposive activity aimed at satisfying needs and conveniences of life. Like Sreenivasan, Simmons sees this as flowing from a prior right of people to secure their subsistence, but Simmons also adds a prior right to self-government. Labor can generate claims to private property because private property makes individuals more independent and able to direct their own actions. Simmons thinks Locke’s argument is ultimately flawed because he underestimated the extent to which wage labor would make the poor dependent on the rich, undermining self-government. He also joins the chorus of those who find Locke’s appeal to consent to the introduction of money inadequate to justify the very unequal property holdings that now exist.