 Nevertheless, many criticisms of the principle of double effect do not proceed from consequentialist assumptions or skepticism about the distinction between intended and merely foreseen consequences. Instead they ask whether the principle adequately codifies the moral intuitions at play in the cases that have been taken to be illustrations of it. One important line of criticism has focused on the difficulty of distinguishing between grave harms that are regretfully intended as part of the agent’s means and grave harms that are regretfully foreseen as side effects of the agent’s means. Since double effect implies that the latter may be permissible even when the former are not, those who wish to apply double effect must provide principled grounds for drawing this distinction. The application of Double Effect to explain the permissibility of performing a hysterectomy on a pregnant woman and the impermissibility of performing an abortion to save a woman’s life is often singled out for criticism on this score. Lawrence Masek (2010) offers a thoughtful defense of the principle of double effect that proposes to construe what is intended by an agent as narrowly or strictly as possible while also distinguishing between motivating side effects and non-motivating side effects. 