 Another objection to consequentialist accounts focuses not on potential wrongs done to the innocent but rather on the wrong allegedly done to the guilty. Consequentialist punishment, on this objection, fails to respect the person punished as an autonomous moral agent. In Kantian terms, such punishment treats those punished as mere means to achieving some social good, rather than respecting them as ends in themselves (Kant 1797: 473; Murphy 1973). The Kantian prohibition on treating each other ‘merely as means’ is admittedly unclear in its implications (for a useful discussion of how we should understand ‘the means principle’, see Tadros 2011: ch. 6). One might argue that if punishment is reserved for those who voluntarily break the law, it does not treat them merely as means. Indeed, Kant himself suggested that as long as we reserve punishment only for those found guilty of crimes, then it is permissible to punish with an eye toward potential benefits (Kant 1797: 473). As we have seen, though, insofar as such an approach relies on endorsing prohibitions on punishment of the innocent or disproportionate punishment of the guilty, the challenge remains that such constraints appear to be merely contingent if grounded in consequentialist considerations. Conversely, if the constraints are more than merely contingent, it appears that they will be based on some deontological considerations, in which case the overall theory will no longer be purely consequentialist, but rather a mixed theory (see s. 6).