 The wrongdoing is, however, essential. Hence the legal moralist takes murder, fraud etc as ripe for criminalization because they are wrongful. They may (or may not) be wrongful because harmful; but from the fact that harms form a significant subset of wrongs, we should not be tempted to put the cart before the horse. Harms matter a great deal, but this is because they are often a kind of wrong. As Devlin’s fellow legal moralist Michael Moore puts it