Abstract: The Doctrine of Double Effect states roughly that it is harder to justify causing harm as a means to an end than causing harm as a byproduct. The Doctrine is invoked to explain why it is permissible to do things like divert a trolley from hitting five people to hitting one, but wrong to do things like push someone into the trolley’s path to stop it from hitting five others. However, the actual harms one causes play no role in bringing about the good in either kind of case. To solve this problem, Warren Quinn proposed a version of the Doctrine according to which it is particularly hard to justify affecting someone as a means when this causes her harm. I present several counter-examples to Quinn’s account. I examine some alteration...