 A number of writers have sought to explain the consistency of whichever moral ideas they suppose properly shape tort law with the role of luck in negligence liability, and with the fact that tort law has no analog of the criminal law’s category of attempt liability (Alexander 1987; Ripstein 1998; 2007; Ripstein &amp; Zipursky 2001; Waldron 1997; Goldberg &amp; Zipursky 2007).