 The possibly problematic inclusion of anencephalic infants does not seem to apply to the view underlying Little’s (2008) claim that FMS is achieved late in pregnancy (pp. 332 and 348), when the fetus, which was a human organism, becomes a human being (pp. 339–341). She does not state what the criteria are for being a human being, but she may be partially following Quinn 1984 and conceiving of a human being as one who belongs to the human species and has the capacity to learn (see her page 340), where the latter feature would exclude the anencephalics. While on this view being a human being is not a merely biological matter, the view is still open to the problem of arbitrariness insofar as it holds that the morally irrelevant, merely biological feature of membership in the human species does make a difference to moral status.