 Recent accounts of noncomparative harm (Harman 2009; Shiffrin 2012, 1999) provide additional reasons to challenge the inference from disability as harm to disability as negative difference-maker. These accounts reject the prevailing, counterfactual analysis of harm as a setback to an individual’s interests with reference to some baseline—her past, her expectations, or the average of her group or society. Instead, they understand harms as fundamentally bad states or events, like pain, disability, and death; states or events that (proponents of these accounts claim) can be regarded as bad without reference to any baseline. On these views, an individual is harmed merely by suffering pain or injury, regardless of whether that pain or injury leaves her worse off overall. She is harmed by painful life-saving surgery, although that averts a greater harm, or life-transforming disability, although her life may go much better as a result.