 Although analysis of ‘the hybrid theory’ of punishment has tended to focus on Hart’s version of it, one might endorse hybrid views that vary significantly from Hart’s. For example, whereas Hart endorsed a consequentialist rationale for punishment and nonconsequentialist side-constraints, one might instead endorse a retributivist rationale constrained by consequentialist considerations (punishment should not tend to exacerbate crime, or undermine offender reform, etc.), or constrained by nonconsequentialist (but not retributivist) considerations such as human rights or respect for persons. Alternatively, one might endorse an account on which both consequentialist and retributivist considerations features as rationales but for different branches of the law: on such an account, the legislature determines crimes and establishes sentencing ranges with the aim of crime reduction, but the judiciary makes sentencing decisions based on retributivist considerations of desert (M. C. Altman 2021; Rawls’s account (1955) has also been characterised as a hybrid view of this sort, but in fact it is a version of rule utilitarianism; on the variety of hybrid views, see Hoskins 2021).