 Some scholars, such as Charles Hallisey (1996) and Jay Garfield, have concluded that it is futile and misleading to try to interpret Buddhist ethics as a systematic theory fitting into one of the recognized types of ethical theories in the West. Rather, they suggest that Buddhist ethics is pluralist, in that it draws on various kinds of moral considerations in different cases, and particularist, rejecting the entire enterprise of formulating general moral principles to cover all cases. This view can easily accommodate textual evidence of various kinds of moral reasoning used by Buddhists in different situations. But since the resulting interpretation lacks an overarching structure, it has few theoretical resources to adjudicate conflicts between different values, and it may become quite unclear what the view says about particular difficult cases.