 One such sort of case that arose in the mid-twentieth century is the so-called “Desert Island” case, where a promise is made in isolation (on a desert island) to someone who then dies. The case was wielded against act utilitarians, as an example of a sort of case that the expectationalist sort of views they espouse can’t answer (see Nowell-Smith 1956; Narveson 1963: 210; Cargile 1964; Narveson 1967: 196–7).