 Most recently, some utilitarians have drawn on institutional theory or game theory in defence, or in modification, of utilitarianism (see Hardin 1988, Goodin 1995, Bailey 1997). Noting that the consequences of individual actions are rarely determined in isolation, but rather in conjunction with the actions of many others, these ‘institutional’ or ‘indirect’ utilitarians argue that morally intuitive institutions such as constitutional rights, human rights and various property rights would be endorsed by this modified utilitarianism, and would forbid the morally horrible outcomes critics have feared utilitarianism could sanction.