 Critics argue that even if Card is correct that it is reasonably foreseeable that the institution of marriage will lead to intolerable harms, it is too heavy-handed to call marriage an evil institution. For instance, Todd Calder has argued that an institution should be considered evil only if intolerable harm is an essential component of the institution. Since suffering and a loss of social vitality are essential components of genocide, genocide is an evil institution. But since spousal abuse is not an essential component of marriage, marriage is not an evil institution (Calder 2009, 27–30).