  Whether or not actions are treated as events, one might be tempted to distinguish between actions proper (such as John’s raising of his arm) and bodily movements (such as John’s arm rising), or between intentional actions (John’s walk) and unintentional ones (John’s falling into a hole). For some authors, this is necessary in order to explain important facts of human behavior (Montmarquet 1978; Hornsby 1980a,b; Searle 1983; Brand 1984; Mele 1997). However, it has also been argued that such distinctions do not pertain to metaphysics but rather to the conceptual apparatus by means of which we describe the realm of things that happen. On this view, an arm raising is just an arm’s rising under a mentalistic description (Anscombe 1957, 1979; Sher 1973).