 Elizabeth Brake advances another challenge to causal views of parenthood. Brake (2005, 2010) argues that we are mistaken to think that being causally involved in creating offspring suffices for acquiring parental responsibilities. According to Brake, many of the social practices that causal theorists appeal to, like child maintenance obligations in accidental pregnancy cases, are in fact mistaken. Brake argues that instead, we ought to be voluntarists about parenthood. This does mean that those who cause children to exist are free from obligations altogether. Brake argues that we ought to distinguish between what she calls ‘procreative costs’ and the more demanding obligations of parenthood. While causal actors may be responsible for procreative costs, they certainly do not have parental responsibilities. More will be said about Brake’s procreative costs in  section 1.4 