  However, it is too simple to say that direct discrimination simply is intentional discrimination. Lippert-Rasmussen rightly points out that there can be cases of direct discrimination not involving the intention to disadvantage anyone on account of her group membership (2014: 59–60). A disadvantage might, instead, be imposed as a result of a general indifference toward the interests and rights of the members of a certain group.  Thus, an employer might use hiring criteria that unfairly disadvantages women, not because the employer intends to disadvantage women, but because the criteria are easy to use and he simply does not care that women are unfairly disadvantaged as a result.  Such instances of discrimination might not have the paradigmatic status that an example like the Roma case has, but they should be counted as forms of direct discrimination, because the disadvantageous treatment derives from an objectionable mental state of the agent.  The same goes for disadvantageous treatment that is the product of bias against a certain group, even when the bias does not involve an intention to treat the group disadvantageously.  A paternalistic employer might intend to help women by hiring them only for certain jobs in his company, but, if the employer is motivated by unwarranted views about the capabilities of women, he is guilty of direct discrimination.