 At this point, it is worth discussing the relationship between the doing/allowing distinction and the famous Trolley Problem. The Trolley Problem dates back to Philippa Foot’s (1978) discussion of a pair of examples: In the first case, a judge must choose between framing and killing an innocent man and allowing five innocents to be killed in a riot. In the second, a trolley driver must choose between turning a trolley so that it runs over an innocent man attached to a track and allowing the trolley to run over and kill five innocent people. Foot, claimed that it was wrong to kill in the first case, but not wrong in the second. Foot noted that such cases might motivate someone to accept the Doctrine of Double Effect, which distinguishes between harm that is strictly intended and harm that is merely foreseen. However, Foot argues that the cases can be explained by the distinction between doing and allowing harm: the judge must choose between killing one and merely allowing five to die, while the trolley driver must choose between killing one and killing five. Judith Jarvis Thomson (1986) modified the case so that it was a bystander, not the driver, who had to make the choice. The difference was important, since the bystander is clearly choosing between killing and letting die and yet it still seems permissible to turn the trolley. This undermines Foot’s claim that the difference between doing and allowing explains our intuitions about these cases. So what made the difference? A considerable amount of ink has been spilled attempting to answer this question.