 The most common objection to consequentialist deterrence theories is that they would allow for manifestly unjust punishments. For example, excessively harsh punishment of the guilty or punishment of the innocent could in principle be justified if it were to effectively serve the aim of deterrence and crime reduction (see McCloskey 1957; Hart 1968; Nozick 1974; Ten 1987; Smilansky 1990; Primoratz 1999; Pereboom 2001, 2014a; Honderich 2006; Boonin 2008; Brooks 2012). This is sometimes called the use objection since it holds that consequentialist theories allow, at least in principle, for the use of persons to achieve certain desirable ends, in violation of the Kantian intuition that persons should be treated as ends-in-themselves. There are, however, a number of common responses to this objection. One is to argue that such ‘unjust’ punishments would be justified if they would really produce the best consequence (e.g., Smart 1973: 69–72; Bagaric &amp; Amarasekara 2000; taken from Duff &amp; Hoskins 2017). Another is to argue that in the real world it would be extremely unlikely that such punishment would ever be for the best, and even less likely that the state could be trusted to reliably pick out those rare cases in which they would be—thus the criminal justice system should adopt the view that such punishment is wrong and unjustifiable (see Rawls 1955; Hare 1981; paraphrased from Duff &amp; Hoskins 2017). Finally, some reply that a richer or subtler account of the ends that the criminal law should serve will generate suitable protections against unjust punishments (see Braithwaite &amp; Pettit 1990; Tadros 2011).