 Although Rudinow’s case provides a clear contrast between what we might call psychological manipulation and situational manipulation, this distinction—or at least its importance—is not always so clear. Consider  tactic 9  above, where Irving threatens to withdraw his friendship if Tonya does not do as Irving wishes. Is this direct psychological manipulation, or situational manipulation? The criterion offered by Barnhill and others counts it as situational manipulation, since Irving changes Tonya’s choice situation so that doing Y and retaining Irving’s friendship is no longer an option. But how is this tactic any less of a direct interference with Tonya’s decision than if Irving had engaged in some form of deception? Why would it be more like what the malingerer does to the police officer than what he does to the psychiatrist?