Certain secularists such as Richard Dawkins, Sam Harris, and the late Christopher Hitchens, often referred to as “New Atheists,” are the latest to tell us that we should look to rationality and science to figure out what to think about important moral issues. These New Atheists generally reject the notion that there can be independent moral truths or that actions can be intrinsically wrong; and they reject the notion of absolute moral rules. They maintain that morality informed by spiritual or religious considerations should be rejected.
I want to examine some aspects of this position as a general matter which, in many ways, is really not new with the New Atheists. I want also to discuss how this position affects our thinking about animal ethics given that, for the past several years, I have noted an increase in animal advocates who believe that animal rights are able to be grounded securely on rationality and science alone and who reject the notion that there can be independent moral truths or that actions can be intrinsically wrong.
Let me make two points at the outset: First, this is an involved issue that requires more than a single blog post. I am offering my preliminary thoughts here and will have much more to say at a later time in work that I am doing on moral realism and animal rights.
Second, I want to stress that if we reject scientific rationality as providing what we need to know about morality, we are not relegated to embracing “supernatural” beliefs or retreating to some sort of moral relativism or subjectivism. One may subscribe to views about moral realism or may accept the principle of nonviolence as a moral truth, for example, without subscribing to views about a creator deity or the survival of personality past death. Indeed, part of the problem is that this debate is often characterized as one requiring that, if we reject relativism, subjectivism, or some similar view, we must choose between the supernatural or scientific rationality. That is a false choice.
Please Choose One: Utilitarians or Jihadists:
Literary theorist Terry Eagleton notes in his review of Dawkins’ The God Delusion: “Apart from the occasional perfunctory gesture to ‘sophisticated’ religious believers, Dawkins tends to see religion and fundamentalist religion as one and the same.”
Moreover, Dawkins also tends to see the notion of rule-based morality as related to religion, and, given that Dawkins tends to equate religion and fundamentalist religion, he draws comparisons between rule-based morality and religious fundamentalism.
For example, in The God Delusion, Dawkins, after paying some lip service to Kant, and noting that although “[d]eontology is not quite the same thing as moral absolutism,” says that “for most purposes in a book about religion there is no need to dwell on the distinction.” He says that although “[n]ot all absolutism is derived from religion. Nevertheless, it is pretty hard to defend absolutist morals on grounds other than religious ones.”
I certainly would agree that we need some form of moral realism to provide a secure foundation for the absolute moral standards that I regard as true: that is absolutely wrong to engage in, for example, the exploitation of the vulnerable; it is absolutely wrong to engage in rape or child molestation or animal exploitation. But it is not necessary to derive the foundation for those standards from religion.
Dawkins notes that, in contrast to deontologists, “[c]onsequentialists more pragmatically hold that the morality of an action should be judged by its consequences,” and he contrasts the “absolutist” with the “consequentialist or utilitarian” who has greater flexibility to consider moral issues. So it appears as though Dawkins is trying to characterize consequential theories, such as utilitarianism, as less likely to be related to the absolutism of fundamentalist religion than rights theories. Sound familiar? Have you ever heard animal welfare supporters, who are always consequentialists of one sort or another, characterize those who support animal rights as “fundamentalists”?
In any event, to the extent that this debate is seen to be a contest between New Atheists or religious fundamentalists who advocate killing abortion doctors, engage in suicide bombing, pray for the apocalypse, fly planes into buildings, promote all sorts of discrimination and hatred, and generally support every conceivable sort of violence in the name of their gods, the New Atheists win easily without the sort of scrutiny and discussion that this matter requires.
But the debate between the New Atheists and others requires more than choosing whether we like utilitarians more than jihadists. The more interesting aspect of the debate focuses on the position that any talk of objective moral truth or absolute moral standards divorced from scientific rationality is problematic and must be rejected if one does not want to be an “enemy of reason.” In this sense, the debate is seen as one between the New Atheists and anyone who maintains that we need some objective, stance-independent moral truth, some absolute moral standards that go beyond what science is able to tell us. Although religious extremists certainly fall into this second group, even if they were not anywhere on the scene, the more general controversy would still exist.
I want to focus on those members of the second group who embrace some version of moral realism, or the notion that moral statements report claims that purport to be true or false and that at least some of these claims are true. For example, a moral realist regards the statement, “slavery is wrong” to be similar to the statement, “the chair is brown.” The first statement, like the second, purports to report a fact, albeit a moral one, and both are true if things are as is claimed (slavery is wrong; the chair is brown). Moral realism is not the view that moral truths are constructed, or made true, as a result of what people value morally; rather, moral truths exist independently of any perspective, including ideal perspectives. I also want to include in this second group, in addition to moral realists, those who have views connected with non-Western (and often non-theistic) spiritual traditions that promote nonviolence, or who subscribe to traditional theistic religions but who reject the interpretations of those traditions that support violence and hatred and, instead, embrace interpretations that support universal love and nonviolence.
An example of the sort of debate I have in mind (but will not discuss in any detail here) is the one between Christopher Hitchens and Chris Hedges, or between Sam Harris and Hedges. Hedges rejects the sort of religious fundamentalism that serves as the primary target of the New Atheists. But he argues that scientific rationality is not the answer in that both groups are equally intolerant: “Those who do not see as they see, speak as they speak and act as they act are worthy only of conversion or eradication.”
The debate between Hedges and the New Atheists is informed to some degree by the fact that Hedges, a former foreign correspondent and Pulitzer-Prize winning journalist, reported on conflicts in the Middle East, Balkans, Africa, and Central America, and has spent a great deal of time witnessing all sorts of atrocities. He understandably tends to focus the debate on how the New Atheists seem to support things like the Iraq war, as did Hitchens, or the claim by Harris that we are “at war with Islam.”
Although I agree generally with Hedges’ take on the New Atheists, I want to explore the issue from a more general perspective. I argue in the next section that the notion that we ought to act rationally at all is a normative notion that, like the axioms of mathematics, cannot be “proved” and must be accepted as true.
But even if rationality is itself accepted as normatively desirable or even as some sort of formal requirement, we cannot provide answers to moral issues without appealing to moral beliefs that cannot be “proved” within the framework of science and rationality and depend for their truth–if they are true–on something that is independent of contingent desires, standpoints, perspectives, or passions. I then consider a related issue: that science is a social activity that cannot be divorced from political and moral considerations.
Rationality and Moral Truth
Rationality is about the suitability of means to ends. When we say that a person is irrational, we generally mean s/he is choosing means that are inappropriate for a particular end.
Rationality is also about the coherence of beliefs. If I believe “if X then Y” and I also believe “X,” then I ought also to believe “Y.”
But there are two senses in which the claim “we ought to be rational” requires normative notions and the very same unprovable beliefs some pejoratively dismiss.
First, let’s start with the claim “we ought to be rational” without regard for what rationality requires us to do or to believe.
Why? Why “ought” we to be rational at all? Why “ought” we to believe “Y” if we believe “If X then Y” and “X.”
How can we “prove” these “ought” statements?
The short answer is that we can’t prove them. They, like the axioms of mathematics, cannot be proved and have to be accepted as true. That is, the claim “we ought to be rational” is a normative position no more secured than the claim “we ought to be kind to and love each other.”
Now, a comeback might be that, although we cannot prove the truth of the claim “we ought to be rational,” this claim must be true because without it, we could not make claims or have arguments in the first place. But that is simply not the case. Even if we did not recognize the objective truth of rationality, we could still make claims and have arguments that would be valid or invalid. We could just not maintain that someone who did not accept the conclusion of sound argument was being irrational. So this reply still leaves an “ought” to explain at the most basic level.
Second, even if we ignore the foregoing concerns and we accept that we ought to choose the means most conducive to our ends, or that we ought to hold beliefs that are consistent with our other beliefs, what does rationality have to say about what ends we choose and what beliefs we have?
The answer: nothing. Nothing at all.
Rationality is a formal requirement at best and cannot serve to identify what ends we ought to choose or what beliefs we ought to have. For example, engaging in conduct that will bring about the end of the world is irrational if you do not see the extinction of life as a desirable end. But for those who think extinction is valuable because they regard humans as a blight on the earth, or who do not care about future generations, or who value things that cause damage to the planet, environmentally destructive behavior may be perfectly rational. Rationality cannot decide the issue of whether humankind is a blight upon the earth and should be extinguished or whether we have an obligation to ensure that the planet is healthy for future generations because humans have moral value.
Similarly, if I believe “all humans have equal inherent value” and I accept that the members of group X are, in fact, human, then rationality of belief requires that I conclude that members of group X have inherent value equal to other humans.
But, despite philosopher Immanuel Kant’s view that reason requires the recognition of equal inherent value for humans, I may reject egalitarianism because I believe that those humans who excel at art or music have greater inherent value than the rest of us because they enrich our lives in a way that others do not. I may take the position that these “special” humans do not act wrongly if they treat others in a wholly instrumental way. Although Kant makes compelling arguments about equality that I argue in my own work should be extended to nonhumans, there is simply no way that we can, using rationality alone, “prove” that Kant is right. Kant’s theory (with or without my modifications) requires that we hold certain moral beliefs about membership in the moral community and no “objective” rationality can compel us to hold those views.
The choice of ends to value, or of moral beliefs to hold, involves something beyond rationality. And there is no way that anyone can avoid that. New Atheists Hitchens and Harris, and Chris Hedges, are all rational people in that they accept that their beliefs ought to be consistent with each other. But they have very different moral beliefs.
It is interesting to note that some of the most prominent New Atheists believe, as did Ayn Rand, that rational, atheistic thought leads us in a direction that just happens to fit with a right-wing world view. As mentioned previously, Hitchens was a strong defender of the Iraq war and held a number of right-wing views and Sam Harris tells us that we are “at war with Islam” and states: “The link between belief and behavior raises the stakes considerably. Some propositions are so dangerous that it may even be ethical to kill people for believing them.” Indeed, Harris purports to demonstrate that we can “scientifically” prove that Islam is a morally bad religion.
Whether or not one agrees with these views (I certainly do not), it is rather silly to deny that they reflect belief in certain moral notions that cannot be proved true in some “objective” or non-controversial way. Chris Hedges disagrees with these views and it is not because he is irrational. He simply accepts a different set of moral principles. The debate between the New Atheists, who have all sorts of belief in a variety of normative notions, and people like Hedges, cannot be resolved by any appeal to rationality; it can only be resolved by deciding whose vision of morality you share.
Noam Chomsky describes Harris and Hitchens as “religious fanatics” who believe in the “religion of the state” in that they argue we have to defend the violence and atrocities of the state because it’s being done to ensure human progress and to achieve other wonderful consequences.
This notion that the world is moving in a positive direction also finds expression in Dawkins, who defends some complete gibberish called the “moral Zeitgeist” that he describes as a “broad liberal consensus of ethical principles” that we are moving toward and that is not driven by religion and that develops despite religion. Putting aside that some of the values he describes positively have been driven primarily by nonviolent interpretations of religious and spiritual traditions, some of the arguments he makes to show that things are getting better are quite remarkable. For example, he tells us that Hitler “would not have stood out in the time of Caligula or Ghengis Khan.” He acknowledges that there have been civilian casualties in Iraq, but they are “orders of magnitude lower than comparable numbers for the Second World War.” Putting aside that Dawkins judges wars morally by the number of casualties (should we just, say, invade countries that have no armies?; that would certainly reduce casualties), the “moral Zeitgeist” is on the move because fewer people died in a fabricated “preventative” war against a nonthreatening adversary (Saddam Hussein) than died in a war against Hitler, who was himself a big step forward from Caligula.
Frankly, I find Dawkins’ views here to be reactionary in a breathtaking way.
Interestingly, Sam Harris claims to be a moral realist. But just as my claiming to President of the United States does not make me President, Harris’ claiming to be a moral realist does not make it so. Moral realism is, in the words of Russ Schafer-Landau, in his book Moral Realism: A Defence (Oxford 2003), the belief that “there are moral truths that obtain independently of any preferred perspective, in the sense that the moral standards that fix the moral facts are not made true by virtue of their ratification within any given actual or hypothetical perspective.” It does not appear to me that Harris is a realist in this sense.
Although Harris is not clear, he appears to be arguing that, because of the sorts of beings we are, we cannot help but value well-being, which we treat as objectively valuable, and regard ourselves as morally obligated to generate as much well-being as possible. That would make Harris a constructivist in that what he is saying on this interpretation is that well-being is made to be a “true” moral value as a result of our perspective.
Alternatively, Harris may be claiming that, as a matter of the meaning of language, claims about morality are really descriptive claims about well-being and science can tell us whether those claims are true or false. That is, just as we say that we cannot engage in science without valuing a certain sort of evidence, coherence, etc., because that is just what is, by definition, to do science, we cannot engage in moral activity without valuing well-being because that is, by definition, what it is to engage in moral activity. Therefore, when we say, “John ought to do action A” what we mean is that “If John does A, well-being will likely happen.” Science can tell us whether and to what extent A will produce well-being. But that involves a simple semantic deflation (Harris says that moral statements are “identical” to factual statements about well-being) and allows Harris to avoid (in his view) the is/ought problem. There is no appeal to any ultimate normative standard as objectively true. This is not a position of moral realism.
If Harris is read as saying that that well-being is valuable in the sort of stance-independent way that Shafer-Landau contemplates and that we are obligated to maximize it, then he is just another consequentialist thinker and adds nothing new to ethical theory except, perhaps, for introducing the notion that we can “scientifically” prove his ethnocentric and xenophobic pronouncements, such as that Islam is a morally bad religion.
Getting an “Ought” from the “Is” Claims of Science
The New Atheists, or some of them, tell us that notions of objective or stance-independent moral truth, or spiritual or religious beliefs, cannot tell us what “is.” Only science can tell us what the “real” facts are. Science provides objective Truth. Everything else is something less than Truth.
Again, this view ignores that the metatheories that establish what is regarded as “science” are, like the axioms of mathematics or the position that rationality is a formal requirement, things that must be accepted as true and cannot be proved to be true. Although those subscribing to New Atheism might accept this as an abstract proposition, they fail to understand its meaning for their enterprise.
Thomas Kuhn in The Structure of Scientific Revolutions, probably the most influential book on the philosophy of science written in the 20th century, popularized the use of “paradigm” to describe the scientific achievements that serve for some period of time to determine what is to be observed, what sorts of questions are to be asked, how any investigations are to be structured, and how results of investigations are to be interpreted. Kuhn argued persuasively that paradigms could not be proved true or false and that it was naive to view science as “Truth.” Different paradigms represent different worldviews; different points of view.
Paul Feyerabend in works such as Against Method pushed this notion even further, arguing against the rationalist idea there are identifiable rules of scientific method that determine what science is “good” science. Feyerabend promoted the notion that science involves more myth than scientists want to acknowledge and that success by scientists has often involved non-scientific elements, including inspiration from mythical or religious sources. Feryerabend made clear that the line with science on one side and religion, myth, magic, and everything else on the other side, is as much of a myth as what scientists claim to reject as myth.
But even if you do not accept what Kuhn, Feyerabend (and many others) have said about the assumptions that science must make and that cannot be proved, or that there is no bright line between science and religion, it cannot be seriously believed that science as practiced is somehow separate from political and social institutions. As Richard Levins and Richard Lewontin pointed out in their groundbreaking book, The Dialectical Biologist, science occurs within a social context and reflects an inherently political perspective.
To understand this point, let us look at an example involving Richard Dawkins’ 1976 book, The Selfish Gene. Is Dawkins making a “scientific” claim about the “facts” of genes, or is he instead focusing on human selfishness and altruism and using these human behaviors to provide a supposedly “scientific” description of the evolutionary process as a general matter, which he then uses to explain human selfishness and altruism? I believe, with philosopher Mary Midgley and others, that the position that Dawkins proposes is a hypothesis that relies more on the reductive individualism of the Enlightenment than it does on Darwin’s views, which, as Midgley argues, involved interaction and cooperation, and that the selfish gene is not some fact of nature. It is fascinating to note that Dawkins’ book became popular precisely at the time that the Reagan/Thatcher notions about the desirability of selfishness, independence, and individualism became popular.
Sam Harris states explicitly as a “fact” that we are “at war with Islam.” Does that “fact” represent an objectively true “is” statement, or does it merely reflect Harris’ adherence to certain political beliefs that determine how he interprets what is happening in the world and the “facts” that he finds? Harris claims that the Taliban morality is bad “from the point of view of science.”
Science tells us that we ought to believe what the evidence appears to show. That is itself a normative claim. But let’s assume that we ought to believe what the evidence shows. What counts as evidence? The answer is that certain evidence, which is consistent with the assumptions of the scientific paradigm, counts, but all other evidence is excluded and ignored. There can be completely different sorts of empiricism (the theory that all knowledge comes from the senses as opposed to being innate). It is incorrect to say that moral realism or all spiritual traditions are unconcerned with evidence or that there is no evidence for them. There is a concern for evidence and there is evidence; it is just not recognized as “scientific” knowledge because science rejects that sort of evidence from the outset. There are many things to measure; science measures only some and even defines how measurement can proceed. Everything else is ignored.
And, as William James maintained, we may be justified in having spiritual or religious beliefs even though we do not have evidence for those beliefs.
The New Atheists offer an incomplete and impoverished choice: a false dichotomy between religious fundamentalism and, what is, in effect, scientism, or “an exaggerated trust in the efficacy of the methods of natural science applied to all areas of investigation (as in philosophy, the social sciences, and the humanities).” But assuming that science can provide us with some uncontroversial “is” statements, we can’t get any “ought” statements from those “is” statements. As Chris Hedges notes: “The belief that rational and quantifiable disciplines such as science can be used to perfect human society is no less absurd than a belief in magic, angels and divine intervention.”
The belief that science provides us with “true” answers to significant moral questions has been shown repeatedly to have the most profoundly disturbing results. Science told us that women would be physically damaged if they had too much education; indeed, science has repeatedly been used to justify discrimination on the basis of sex. Science told us that people of color were physically and cognitively different from white people as a “factual” basis for the justification of human slavery. There are countless examples of how science has been used to justify a great deal of violence and a wide range of discrimination.
A critic may counter that science has been used to support good moral ends as well. For example, scientists eventually abandoned “scientific” claims about the supposed physical inferiority of women. But that’s the point. It’s not science that drives morality; it’s morality (and immorality) that drives the science. To take a (very) loose analogy from quantum theory: our moral consciousness determines the reality we see.
Atheism and Animal Rights
Many animal advocates claim to be atheists. They are in error if they think that there is some notion of “objective” rationality, or some combination of rationality and scientific facts, which, though rejecting moral premises, can secure the moral conclusion that we ought to stop exploiting animals.
The abolitionist philosophy that I have developed certainly relies on rational argument but ultimately rests on a foundation of moral realism. For example, when I state, “it is wrong to inflict suffering on a sentient being without an adequate justification,” I mean that to be a principle that represents a moral fact. From this principle, together with the logical premise that the moral notion is meaningless if an adequate justification can include the pleasure, amusement, or convenience of the person(s) imposing the suffering, I argue rationally to the conclusion that we cannot justify most animal use, however “humane” it might be. (I have other arguments against any animal use that is not ruled out by the “necessity” argument.)
So the theory (or that part of it) rests on logic and rationality, and certain nonmoral facts about animal sentience. But you cannot get to any normative conclusion if you don’t agree with the moral fact that it is wrong to inflict suffering on another sentient being without an adequate justification. If you ask me to “prove” the truth of that moral fact using a framework prescribed by science or in a way that every rational person would be compelled to accept, I can’t. That does not mean that “it is wrong to inflict suffering on animals without an adequate justification” is not a moral fact; it does not mean that no evidence supports it. My views are based on moral intuitions, which involve beliefs that are based in experience, but which cannot be “proved” with the sort of evidence that is used in the prevailing paradigm of science. I would, however, maintain that the truth of the moral intuition, “it is wrong to inflict suffering on animals without an adequate justification,” is self-evident, even though its truth does not rest on observation.
Another argument that I make is that if animals are to have any moral significance at all, we must accord them the right not to be treated as property. I argue further that according them that one right requires the abolition of all institutionalized animal use, however “humane.” As in the case of the previous argument, I am relying on a moral intuition: that animals do count morally even if there are cognitive differences between humans and nonhumans. If you share that intuition–if you accept the moral fact that animals matter morally–then rationality requires that you recognize that animals have a pre-legal, basic right not to be property. But rationality does not require that you recognize that animals are not merely things.
Moreover, Peter Singer and others who advocate a welfarist position recognize that animals have morally significant interests but argue, contrary to my position, that we can, as a moral matter, maintain the institution of animal property because animals are not reflectively self-aware in the way that humans are and do not have an interest in continuing to live. Therefore, we may use and kill animals for human purposes as long as we treat them in a way that accords sufficient moral consideration to the interests that they do have, particularly the interest in not suffering.
Therein lies another important matter that cannot be resolved merely by an appeal to rationality or the facts of science. Singer and I agree that sentience is all that is needed for animals to be morally significant, but we disagree in that Singer does not regard sentience as sufficient to give rise to the interest in continued life that, for Singer, is necessary to have at least prima facie moral protection against being used as a resource. I do regard sentience as sufficient to give rise to an interest in continued existence and I argue that this interest should be protected not only as a prima facie matter, but as a matter of moral right, and that we cannot justify any animal use.
Putting aside that I recognize moral rights and Singer does not (another issue that cannot be resolved by an appeal to scientific rationality), there is a sense in which my disagreement with Singer in this regard looks, at least in part, like a factual matter that can be resolved by some sort of “scientific” discovery about animal self-awareness. That is, he says that most animals do not have an interest in continued existence because they are not self-aware; I deny that. Although there is a factual component to this concerning the nature of animal consciousness, there is, more importantly, a non-factual aspect that science cannot resolve as to what counts as self-awareness for moral purposes. Singer maintains that the self-awareness that matters is reflective self-awareness and that most nonhumans are not self-aware in this way; I accept that most animals are probably not reflectively self-aware but I maintain that this is irrelevant in that the only self-awareness that matters for having an interest in continued existence is that which is incidental to the perceptual awareness that requires nothing more than sentience.
So Singer and I may agree on the facts of animal consciousness but come to different conclusions because of our differences as to what ought to be regarded as the sort of self-awareness that counts for having an interest in continued existence. In any event, rationality and science cannot resolve these sorts of disagreements.
Rationality and a Revolution of the Heart
I often say that ending animal exploitation requires “a revolution of the heart.” What I mean by that is that we must reject all ideologies of domination and power, whether religious or secular, that allow us to transform other sentient beings–human or nonhuman–into the “other,” thereby allowing us to ignore their moral value and to treat them as things. We must embrace nonviolence as a basic normative principle–a principle that we see as reflecting a moral truth–and as the foundational moral principle from which all our moral positions flow. Philosopher Gary Steiner’s notion of kinship links up directly with these ideas.
I believe that many spiritual and religious traditions, properly understood, regard nonviolence as a primary value. I reject any that do not. I do not, however, reject them because they are “irrational”; ideologies of power and domination may be perfectly rational if your moral compass points you to them. I reject ideologies of power and domination, whether religious or secular, because they are, in my view, morally in error.
A revolution of the heart requires that we recreate ourselves consistent with the highest aspirations common to all traditions that recognize the importance of nonviolence, and that we reject any framework that promotes violence, discrimination, prejudice, and hatred.
Part of the attraction of the New Atheists is that everyone, including those who may once have embraced a traditional religion, is sick and tired of the violence–the hatred, prejudice, discrimination, wars, materialism, etc.–that is promoted by some institutionalized religions. Rejecting that hatred and violence is a good thing. Many animal advocates correctly note that traditions such as Christianity, Judaism, and Islam have been interpreted to justify speciesism and animal exploitation. This had led a number of these advocates to declare themselves as hostile to spiritual beliefs or to the notion of objective moral truth. But perhaps we ought to consider that the real culprit here is not spiritual or religious belief per se, but the violence that some of these traditions have been interpreted, rightly or wrongly, to promote.
To the extent that violence of any sort is thought to be approved of by “god” or by religion, getting rid of the god or the religion does not necessarily result in peace, love, and justice. Secular institutions promote violence as well.
New Atheist Christopher Hitchens said, “I am absolutely convinced that the main source of hatred in the world is religion, and organized religion.” I disagree. Hatred is the problem; neither religious nor secular institutions cause hatred. They simply provide a mechanism to express it.
I accept that the concept of a revolution of the heart rests on a moral notion that cannot be proved to be “true” in the way that science characterizes truth and given what science regards as acceptable evidence. It requires belief in the moral truth of nonviolence. And scientific rationality cannot get us to that, or to any, moral truth.
If you are not vegan, please go vegan. It is easy and better for your health and for the environment (assuming that you value your health and the environment but rationality does not require that you do so). But, most important, it is the morally right thing to do (but that is a moral conclusion that rests on an argument that includes moral premises that cannot be derived from scientific facts or some non-normative notion of rationality).
Gary L. Francione
Professor, Rutgers University
©2012 Gary L. Francione