  Let us consider first a type of freedom associated with the range and quality of actions open to a person. One gets an intuitive idea of this sort of freedom in comparing the situation of a prison inmate to that of someone outside prison. Someone confined to a cell around the clock has less freedom than does someone who is able to move about as she wills, interact with others in a variety of ways, and choose from a broad variety of activities (at least if she has available sufficient means to pursue them). We might be tempted to say that the unincarcerated person has more and better choices of actions. But several difficulties get in the way of making such a comparison precise. We lack a precise way to enumerate actions, which seems necessary if we are to count them or compare their number. The incarcerated and unincarcerated both have indeterminately many different things they can do, each can do only perform some small range of those actions at any one time. (It's even likely that the incarcerated person can do some things the unincarcerated  person  can't.[23]) So it is probably more helpful to focus on the greater quality and desirability of the actions open to the unincarcerated person. Being confined to a jail cell takes away one's freedom at least in part because it denies one the necessary means to pursue many other activities that would ordinarily be desirable. But we also have no good means for reckoning the value of different actions interpersonally. So even this comparison is hard to make in a robust, defensible  fashion.[24]