 On the other end of the spectrum, more scholars have adopted the view of Dunn (1969), Tully (1980), and Ashcraft (1986) that it is natural law, not natural rights, that is primary. They hold that when Locke emphasized the right to life, liberty, and property he was primarily making a point about the duties we have toward other people: duties not to kill, enslave, or steal. Most scholars also argue that Locke recognized a general duty to assist with the preservation of mankind, including a duty of charity to those who have no other way to procure their subsistence (Two Treatises 1.42). These scholars regard duties as primary in Locke because rights exist to ensure that we are able to fulfill our duties. Simmons (1992) takes a position similar to the latter group, but claims that rights are not just the flip side of duties in Locke, nor merely a means to performing our duties. Instead, rights and duties are equally fundamental because Locke believes in a “robust zone of indifference” in which rights protect our ability to make choices. While these choices cannot violate natural law, they are not a mere means to fulfilling natural law either. Brian Tierney (2014) questions whether one needs to prioritize natural law or natural right since both typically function as corollaries. He argues that modern natural rights theories are a development from medieval conceptions of natural law that included permissions to act or not act in certain ways. 