 Some have contended that punishment with a consequentialist rationale does not treat those punished merely as means as long as it is constrained by the retributivist prohibitions on punishment of the innocent and disproportionate punishment of the guilty (see Walker 1980: 80–85; Hoskins 2011a). Still, a critic may argue that if we are to treat another with the respect due to her as a rational and responsible agent, we must seek to modify her conduct only by offering her good and relevant reasons to modify it for herself. Punishment aimed at deterrence, incapacitation, or offender reform, however, does not satisfy that demand. A reformative system treats those subjected to it not as rational, self-determining agents, but as objects to be re-formed by whatever efficient (and humane) techniques we can find. An incapacitative system does not leave those subjected to it free, as responsible agents should be left free, to determine their own future conduct, but seeks to preempt their future choices by incapacitating them. And although a deterrent system does, unlike the others, offer potential offenders reason to obey the law, it offers them the wrong kind of reason: instead of addressing them as responsible moral agents, in terms of the moral reasons which justify the law’s demands on them, it addresses them as merely self-interested beings, in the coercive language of threat; deterrence treats ‘a man like a dog instead of with the freedom and respect due to him as a man’ (Hegel 1821: 246. For these objections, see Lewis 1953; H Morris 1968; Duff 1986: 178–86; von Hirsch 1993: 9–14; von Hirsch and Ashworth 1998, chs. 1, 3).