 Quinn contrasts his status approach to rights with one that ascribes rights “because such an arrangement best promotes overall human welfare.” His target is consequentialist theories of rights, the paradigm of which are utilitarian theories. We met such a utilitarian theory of rights above in John Stuart Mill’s conceptualization of rights as “something which society ought to defend me in the possession of.” Mill believed that society ought to defend the individual in possession of her rights because doing so would bring about the greatest utility summed across the members of that society. For Mill, as for other instrumental theorists, rights are a tool for producing an optimal distribution of interests across some group.