 The key difference for Quinn is between cases where the agent produces the result by an action and cases where she produces it by an inaction—pushing someone’s head under water or refraining from throwing a life preserver. Quinn holds that we do not need further analysis of the action/inaction distinction. However, Quinn adds a modification to his account which means that he does not treat the doing/allowing distinction and the action/inaction distinction as the same. Sometimes, Quinn says, your relevance to a death can be positive, you can kill, in other words, even though you don’t act. This happens, for example, when you are on a train headed towards some drowning victims you wish to save when you notice someone tied to the tracks ahead of you. You can stop the train but you choose not to in order to reach your destination. Quinn believes that you kill in this case, because the train acts as your agent, taking you where you want to go, and crushing the person tied to the tracks in the process. On the other hand, if you had chosen not to stop the train for some other reason but you would have not minded had someone else stopped the train, then your failure to stop the train would not have constituted a killing.