The Trouble with Kant’s Humanity Formula Andrew Johnson It is probably safe to say that, of Kant’s various formulations of the Categorical Imperative, none has been more well-received than the Humanity Formula. “So act that you use humanity, whether in your own person or in the person of any other, always at the same time as an end, never merely as a means” (G 4:429).1 As against Utilitarianism, the Humanity Formula seems, more clearly than Kant’s Universal-Law Formula, to uphold the widely accepted view that persons have certain inviolable rights. Persons may not be enslaved or raped, they may not be punished without having committed a crime, no matter how much happiness such actions might yield others. Prominent Kantian moral philosophers, such as Christine Korsgaard, Allen Wood, and Alan Donagan, have defended the Humanity Formula as a basic moral principle of theoretical ethics.2 Moreover, it has frequently provided inspiration for arguments in applied ethics. Examples include Denis Arnold’s and Norman Bowie’s critique of sweatshops,3 Onora O’Neill’s argument for famine relief,4 and Barbara Herman’s analysis of sexual objectification.5 1 All translations of Kant’s moral writings are taken from Immanuel Kant, Practical Philosophy, trans. and ed. Mary J. Gregor (Cambridge: Cambridge University Press, 1996). 2 See, e.g., Christine Korsgaard, The Sources of Normativity (Cambridge: Cambridge University Press, 1996), espe- cially pp. 122ff.; Allen Wood, Kant’s Ethical Thought (Cambridge: Cambridge University Press, 1999), pp. 111–55; Alan Donagan, The Theory of Morality (Chicago: University of Chicago Press, 1977). 3 Denis Arnold and Norman Bowie, “Sweatshops and Respect for Persons,” Business Ethics Quarterly 13 (2003). 4 See, e.g., Onora O’Neill, “Rights, Obligations and World Hunger,” in Poverty and Social Justice: Critical Per- spectives: A Pilgrimage toward Our Own Humanity, ed. Francisco Jimenez (Tempe, AZ: Bilingual Press, 1987), pp. 86-100. According to Kant, the Categorical Imperative is “the supreme principle of morality” (G 4:392), and it is a principle that is supposed to give us guidance regarding, among other things, the morality of actions. For a principle to qualify as the supreme principle of the morality of actions, it must, I take it, satisfy three conditions. Firstly, it must be fundamental, in the sense that it is not derivable from a still more basic principle of moral action. Secondly, it must be complete, in that it is neither limited to certain spheres of action nor in need of supplementation by additional moral principles. Finally, it must be plausible, not yielding implications that even most proponents of the principle would regard as false. In what follows, I focus on these last two conditions, which I call “the completeness condition” and “the plausibility condition.” My argument will be that the Humanity Formula does not jointly satisfy both conditions. If it is interpreted so as to be complete, it is implausible. If it is interpreted so as to be plausible, it is incomplete. The completeness condition specifies that a supreme moral principle must, at least in theory,6 and without reliance on any further moral principles, be action-guiding in every situation. (Note that one way a principle can be action-guiding is by implying that an action under consideration is morally permissible, though not morally required.) Kant evidently endorses this condition himself. He maintains that “there is only a single categorical imperative” and that “all imperatives of duty can be derived from this single imperative” (G 4:421). Although he states the 5 Barbara Herman, “Could It Be Worth Thinking about Kant on Sex and Marriage?,” in A Mind of One’s Own: Fem- inist Essays on Reason and Objectivity, ed. Louise Antony and Charlotte Witt (Boulder: Westview Press, 1993), pp. 49–67. 6 The qualification “at least in theory” is supposed to block as a decisive criticism of a consequentialist principle of rightness the point that we are sometimes unable to determine which action out of the alternative actions has the best consequences. For obvious reasons, I don’t want in my argument to rely on a stronger necessary condition of adequacy than necessary. 2 Categorical Imperative in a variety of ways, Kant insists that the various formulations “are at bottom only so many formulae of the very same law” (G 4:436). As a version of the supreme principle of morality, the Humanity Formula purports to guide action in any situation in which a moral agent might find herself. Yet, as I will try to show, there is a whole class of situations (what Kant calls “imperfect duties”) for which the Humanity Formula cannot properly guide action unless it is supplemented by some additional moral principle. The plausibility condition is that a supreme moral principle must not have any implications that are or would be widely agreed to be false, even by partisans of the principle. For example, many philosophy students who initially declare themselves partisans of straightforward cultural relativism abandon the view once they see that it sanctions the rankest forms of racism or sexism within deeply racist or sexist cultures. I will make a case that applying the Humanity Formula to particular types of action yields implications that even most Kantians will concede to be false. My argument will also be informed by what I take to be a corollary of the completeness condition’s requirement of “action-guidingness,” namely, the hermeneutical rule that an interpretation of a vague moral principle should not be framed in terms of concepts that are equally vague or vaguer. A facetious example will illustrate the point of such a rule. Were we to interpret the Humanity Formula as equivalent to the injunction of 1 Peter 3:11 to “turn away from evil and do good,” this might inoculate it against any objections. Yet it would render the Humanity Formula useless in precisely those cases for which we would like to have a moral principle: cases in which we are unsure or disagree about what is good and what is evil. In my view, the injunction always to treat humanity in persons as an end, never as a means only, is vague and, to be generally useful, requires interpretation in more specific terms. 3 This contention requires some defense; not all Kantian ethicists would agree with it. Allen Wood, for example, maintains that “[t]he meaning of [the Humanity Formula] is clear and determinate because the concepts of humanity (or rational nature) and existent end in itself are both reasonably clear and determinate.”7 If Wood were right about this, we would not be able to distinguish three possible interpretations of the Humanity Formula on the basis of Kant’s discussion of the false-promising example, whereas in fact we can, as I will presently argue. In addition, some questions about awkward cases for the Kantian can motivate the impression that the Humanity Formula is less than fully precise. Does a prostitute treat humanity in her own person as a mere means? Were families who hid Jews from the Nazis morally prohibited from lying to Nazi soldiers who came knocking? Does a corporation that pays sweatshop workers the barest subsistence wage, although it could afford to pay them significantly more, fail to treat them as ends? Without further analysis of what it is to treat humanity in persons as mere means or as ends, it isn’t clear what answers the Humanity Formula implies to such questions. Furthermore, analyzing the Humanity Formula as a requirement “to respect every human being, oneself or any other, as a rational creature,”8 or always to treat persons with dignity, or not to interfere with persons’ autonomy, or to treat persons in accordance with rational principles, does not resolve the difficulty. For intuitions about the nature of respect, dignity, autonomy, and rational principles will likewise diverge with respect to controversial cases. In the interests of adding precision to the Humanity Formula’s injunction, we may note that it lays down two requirements. Firstly, we should not treat humanity in persons as a mere means; call this the ‘negative requirement.’ Secondly, we should treat humanity in persons as an 7 Op. cit., p. 154. 8 Donagan, op. cit., p. 66. 4 end; call this the ‘positive requirement.’ While these two aspects of the Humanity Formula are not logically equivalent to each other, some commentators have pointed out that there is fundamentally just one requirement: to treat humanity (in Kant’s idiosyncratic sense) as an end, with the requirement to avoid treating humanity as a mere means being a narrower logical implication.9 I agree that, conceptually, one cannot treat a person as an end and simultaneously treat him as a mere means. However, I argue in what follows that, when it comes to applying the Humanity Formula, the requirement to treat humanity as an end cannot stand alone. In speaking of humanity as an “end,” Kant is not using the term in its standard sense of a goal or purpose to be achieved. Ends of this sort Kant regards as subjective ends, whereas human beings (or at least those possessing practical reason) are objective ends (G 4:431). Objective ends are ends in themselves, not in the traditional sense of being subjectively valued for their own sakes, but in the sense of having an inviolable dignity not deriving from subjective human attitudes. Objective ends constitute morally necessary side-constraints on our subjective ends. In Kant’s words, “a rational being, as an end by its nature and hence as an end in itself, must in every maxim serve as the limiting condition of all merely relative and arbitrary ends” (G 4:436). This passage provides a clue as well to what Kant means by ‘humanity.’ What is morally crucial about humanity in a person is its identity with—or perhaps inclusion of—the person’s rational nature, which encompasses the person’s capacity for rational agency. Shortly before Kant introduces the Humanity Formula, he affirms that “rational nature exists as an end in itself” (G 4:429). Either this is just a variant formulation of the proposition that humanity exists as an end in itself, or humanity is a subspecies of rational nature. 9 See, e.g., Allen Wood, Kant’s Ethical Thought (Cambridge: Cambridge University Press, 1999), p. 143; and Thomas Hill, Jr., “Treating Criminals as Ends in Themselves,” Jahrbuch für Recht und Ethik, Vol. 11 (2003), pp. 19-20. 5 However, even assuming we have a clear understanding of the concepts of humanity and an end in itself, it isn’t obvious what we must do to fulfill the Humanity Formula’s positive and negative requirements. Kant offers some clarification of his positive requirement as it applies to humanity in others with his beneficence example in the Groundwork. Kant remarks that [h]umanity might indeed subsist if no one contributed to the happiness of others but yet did not intentionally withdraw anything from it; but there is still only a negative and not a positive agreement with humanity as an end in itself unless everyone also tries, as far as he can, to further the ends of others. For, the ends of a subject who is an end in itself must as far as possible be also my ends, if that representation is to have its full effect in me. (G 4:430) Although Kant places no restrictions in this passage on the ends of others which I am to make mine, charity demands we interpret the passage quoted above as requiring that we make only the permissible ends of others our own;10 otherwise the Humanity Formula would have the unacceptable implication that we should adopt the nefarious ends of, e.g., thieves, pedophiles, murderers, and House Republicans. In The Metaphysics of Morals, Kant explicitly issues the needed qualification: “When it comes to my promoting happiness as an end that is also a duty, this must therefore be the happiness of other men, whose (permitted) end I thus make my own end as well” (MM 6:388; parenthesis and italics in original; underlining added).11 Kant, who disdains eudaimonistic ethics (see, e.g., MM 6:377–78), does not operate with a morally sanitized conception 10 Charity also demands, of course, that we hold to a manageable number the range of others whose ends we ought to promote. But this is an exegetical question I shall not enter into here. 11 H. J. Paton is exceptional in recognizing the need for the qualification, noting that “we ought to further the ends of others only so far as they are not manifestly foolish or incompatible with the moral law” (op. cit., p. 173). However, he fails to notice the problem of circularity—which I am about to describe—involved in determining whether an end is “incompatible with the moral law.” 6 of happiness according to which any action that truly contributes to a human being’s happiness is morally permissible. Unlike moral requirements, which hold necessarily for all rational agents who have sensuous natures and thus “inclinations” (Neigungen),12 the ingredients of happiness are a fundamentally subjective matter. Kant holds that “[i]t is for [others] to decide what they count as belonging to their happiness” (MM 6:388). But if the Humanity Formula enjoins us in part to promote the permissible ends of others, then we need a criterion of their moral permissibility. The needed criterion must come either from the Humanity Formula itself or from outside the Humanity Formula. If it can come only from outside the Humanity Formula, then the formula fails the completeness condition. If, on the other hand, the Humanity Formula can supply the requisite criterion of permissible ends itself, then it must be through its negative requirement, since the positive requirement is what gives rise to the need for the criterion of permissible ends in the first place. On this interpretation, the permissible ends of others are those the attainment of which does not entail treating any person as a mere means.13 We could rule out the characteristic ends of thieves, pedophiles, murderers, and House Republicans as worthy of promotion on the grounds that attainment of these ends entails 12 Rational agents who do not have sensuous natures are not subject to moral requirements, or duties, because they necessarily act in accordance with reason and hence morality. The notion of a duty to perform a particular action makes sense only when an agent has the option of omitting the action. See, e.g., CPrR 5:32. 13 I have heard this interpretation proposed by both Jon Tresan and Luke Robinson in conversation. The idea that an irreducibly basic requirement of the Humanity Formula is the prohibition against treating humanity as a mere means cannot, however, be said to be orthodox among Kant commentators. Both Allen Wood (op. cit., p. 143) and Thomas Hill, Jr., (“Treating Criminals as Ends in Themselves,” Jahrbuch für Recht und Ethik, Vol. 11 [2003], pp. 19-20), for example, take as basic the injunction always to treat humanity as an end, with the proscription against treating humanity as a mere means being just a logical implication. Wood puts it starkly: “the phrase ‘never merely as a means’ actually plays no role whatever in the actual content of FH” (ibid.; italics in original). 7 using others as mere means. But, as we shall see, this proposal doesn’t lead to a sound Humanity Formula either, since the formula’s prohibition against using persons as mere means has false implications on textually grounded interpretations. What is it to treat a rational agent as a mere means? Kant offers some clarification in his Groundwork examples of the suicide and the false promiser. Given the controversial nature of Kant’s rather sweeping disapproval of suicide, I shall consider only Kant’s explanation of how the false promiser treats (the humanity of) the promisee as a mere means. On this question, Kant explains that as regards necessary duty to others or duty owed them, he who has it in mind to make a false promise to others sees at once that he wants to make use of another human being merely as a means, without the other at the same time containing in himself the end. For, he whom I want to use for my purposes by such a promise cannot possibly agree to my way of behaving toward him, and so himself contain the end of this action. This conflict with the principle of other human beings is seen more distinctly if examples of assaults on the freedom and property of others are brought forward. For then it is obvious that he who transgresses the rights of human beings intends to make use of the person of others merely as a means, without taking into consideration that, as rational beings, they are always to be valued at the same time as ends, that is, only as beings who must also be able to contain in themselves the end of the very same action. (G 4: 429–430) Ironically, Kant’s explanation may raise as many questions as it answers. It contains, at a minimum, three possible analyses of what it is to treat humanity in another as a mere means.14 These analyses involve, respectively, the other’s not actually sharing the agent’s end, the other’s not possibly sharing the agent’s end, and the other’s not possibly agreeing to his treatment by the agent. The analyses aren’t mere exegetical possibilities, but have been employed, as I will illus- 14 “At a minimum,” since further possibilities arise from combining the three basic possibilities in various ways. 8 trate, by leading Kantian ethicists. We need not determine which of the analyses is definitive. For every one of them, I hope to show, spells trouble for the Humanity Formula. The first possible analysis is based on Kant’s assertion that the lying promiser is using the promisee without the promisee “at the same time containing in himself the end.” It suggests the following principle: (NR1) Action a treats (the humanity in) person P as a mere means if and only if a has end e, a cannot bring about e without affecting P, and P does not hold e. Two elements of the analysans, “a has end e” and “P does not hold e,” are straightforward enough; they convey merely that the action in question aims at an end that the recipient of the action does not actually hold. The third element, “a cannot bring about e without affecting P,” may seem a needlessly convoluted variant of the more straightforward “a affects P.” But the latter, unlike the former, has the implausible implication that it is possible to treat as mere means those inadvertently affected by an action.15 Allen Wood affirms an understanding of the negative requirement very much like (NR1). He explains how Kant’s application of the Humanity Formula to the false-promising case clarifies Kant’s earlier evaluation of the case according to the Formula of the Law of Nature: 15 In fact, I believe more needs to be said here about the way a affects P. Consider, for example, a factory that emits pollution into the environment for the end of minimizing costs, though the factory managers know that the pollution will likely be a contributing factor to a number of premature deaths. The managers might claim that their action of polluting doesn’t run afoul of (NR1), since it is possible that their polluting could bring about the end of minimizing costs without having any adverse health effects on human beings (as would be the case if the people exposed to the pollution had exceptionally hardy constitutions). Clearly this isn’t the result a Kantian should want. But I don’t have the space to explore this angle here. 9 If … the giving and accepting of a promise requires the promiser and the promisee to share their ends, then it is clear why the promises falling under U2 [which states that “[i]t is a universal law of nature that when anyone believes they are in need of money, they will borrow it and promise to repay it without having any intention to do so”16] would be impossible, since they preclude such sharing.17 The salient moral fact on the present analysis is that the promisee does not in fact hold the end of the lying promiser, whatever end the lying promiser is aiming at. But if this is what it is for one person to treat another as a mere means, the Humanity Formula is much too restrictive, for it would forbid our treating others justly when they don’t hold the end of being treated justly. It would be wrong to deny an unqualified job applicant a job if she doesn’t hold the end of having the job performed by the most qualified applicant, wrong to fail the “F” student who wants a better grade than he is entitled to, and wrong to punish former presidents and vice-presidents for violations of domestic and international law when they believe they should be able to act with impunity. The next two analyses of treating humanity as a mere means are rooted in Kant’s claim that the promisee “cannot possibly agree to my way of behaving toward him, and so himself contain the end of this action” (G 4:429–30). Christine Korsgaard takes this passage as the basis of her exegesis of the Humanity Formula’s negative requirement, which entails what Kant calls “perfect duties,” or duties which allow “no exception in favor of inclination” (G 4:421n.). The 16 Op. cit., p. 87. 17 Ibid., p. 148. In a striking coincidence, Wood goes on in the next sentence to reproduce Kant’s shift from an actu- al sharing of an end to a possible sharing (“cannot consent”) of it. The shift doesn’t necessarily indicate an inconsistency. It could be that the impossibility of consenting to being treated in a certain way is being cited as evidence that the recipient of the action does not actually share the end of the agent. 10 phrases “cannot possibly agree to my way of behaving toward him” and “cannot … himself contain the end of this action” yield, in Korsgaard’s words, “a test for perfect duties to others: an action is contrary to perfect duty if it is not possible for the other to assent to it or to hold its end.”18 Korsgaard conflates the meanings of these two phrases, although they are in fact importantly distinct. The expression “my way of behaving,” contained in the first phrase, refers to the action I perform as a means to my end, whereas the second phrase refers explicitly to my end. Which expression is more essential to Kant’s explanation of the wrongness of false promising? Suppose for the sake of argument that the more fundamental point for Kant is that the promisee cannot hold the end of the lying promise. If so, Kant cites the impossibility of the promisee’s agreeing with the action as evidence for this point. Then we have the following analysis of what it is to treat humanity in a person as a mere means: (NR2) Action a treats (the humanity in) person P as a mere means if and only if a has end e, a cannot bring about e without affecting P, and P cannot hold e. (NR2) represents an improvement over (NR1) insofar as (NR2) does not render certain kinds of treatment immoral simply because the recipient of the treatment does not share, however unreasonably or immorally, the end of the treatment. (NR2) does not, for instance, exempt lawbreakers from punishment simply because they do not share the ends of the punishment. A lawbreaker can, in principle, share the end society has in punishing him. Yet, whereas (NR1) results in too restrictive a Humanity Formula, (NR2) makes it too permissive. For it is possible for those unavoidably affected by even the most immoral actions to hold the ends of those actions. The end of the car thief may be to enjoy the full-time use of my car, and it is quite possible for me to share 18 Christine Korsgaard, “The Right to Lie,” in her Creating the Kingdom of Ends (Cambridge: Cambridge University Press, 1996), p. 138. Korsgaard’s statement of the phrases in question diverges slightly from mine, as she uses a different translation. 11 that end, as I would if I decided to give my car to him. The end of the rapist may be sexual gratification, and it too is an end it is possible for the rape victim to share (though not, of course, qua rape victim). The end of the false promiser may be to pay off a debt or make a purchase, and there is nothing in principle precluding the promisee from holding this end as well.19 Korsgaard would take issue with this point. She argues that, when you make a false promise, the promisee cannot in fact hold the end of the promise: In cases of violation of a perfect duty, lying included, the other person is unable to hold the end of the very same action because the way that you act prevents her from choosing whether to contribute to the realization of that end or not. Again, this is obviously true when someone is forced to contribute to an end, but it is also true in cases of deception. If you give a lying promise to get some money, the other person is invited to think that the end she is contributing to is your temporary possession of the money: in fact, it is your permanent possession of it.20 The disagreement between Korsgaard and myself raises the question of what is to count as the end of an action. So far I have spoken of the end of an action as if it were unproblematic that every (intentional) action has one and only one end. In fact, an action can have any number of ends. For instance, a person might enroll in college as a means to the ends of becoming a doctor, developing a deeper understanding of American history, and livening up her social life. All of 19 Thomas Hill Jr. attempts to circumvent this problem by adding further conditions for the kind of possibility in question. We conform to the Humanity Formula “by restricting our ends and means to those that anyone affected by us ‘could share’ at least in the sense that they could rationally and reasonable [sic] endorse them” (op. cit., p. 24). While there may be philosophical merit to this proposal, it strikes me as a problematic (route of) interpretation of the Humanity Formula, given that Kant in the Groundwork evidently thought it could be applied to specific actions without need for Hill’s criteria of rational and reasonable endorsement. In fairness to Hill, the paper in question does not claim “strict fidelity to [Kant’s] views” (ibid., p. 25). 20 Op. cit., p. 139–40. 12 these ends might in turn be means to the more final end of her happiness. Hence, even if Korsgaard is right that the promisee in Kant’s example cannot hold the end of the promiser’s permanent possession of the promisee’s money, her interpretation of the Humanity Formula will not establish that it is a sound moral principle until she offers a non-ad hoc reason for fixing on this end to the exclusion of other ends of the promiser that the promisee can hold. But I don’t believe Korsgaard is actually right about this. Suppose, in order to obtain a $100 loan from me, you make a false promise to pay it back; hence you have the end of taking permanent possession of my $100. Suppose, in addition, that I, ever a sucker for your counterfeit charms, want to give you the $100 as a gift, but don’t tell you yet, saving the news as a surprise for your birthday next week. Then we both actually do have the end of your having permanent possession of my $100; a fortiori we can hold the same end. It follows, according to Korsgaard’s interpretation of the Humanity Formula, that you do me no wrong in giving me the false promise. This is not the result we should want. Given the shortcomings of (NR2), then, let us assume that the morally relevant and more fundamental feature of the false promise case is that the promisee “cannot possibly agree to [the promiser’s] way of behaving toward him” (G 4:429–30). What Kant evidently has in mind is the logical impossibility of agreeing to receive a false promise in a particular case. It is logically impossible to make a promise to someone who rejects it out of hand, and someone who knows a promise is false will reject it out of hand (G 4:422). Korsgaard endorses this interpretation of the negative requirement too, as she doesn’t distinguish the impossibility of a patient’s agreeing to an agent’s way of treating him from the impossibility of the patient’s holding the agent’s end. She describes a case very similar to the one I just considered. However, in her case, we are to imagine that I somehow know from the beginning that your promise to repay the loan is a false 13 one, but that I nevertheless want you to have my money. In that event, she rightly points out, “[t]he nature of the transaction is changed: now it is not a promise but a handout.”21 Onora O’Neill is another prominent proponent of this understanding of the Humanity Formula’s negative requirement.22 We can analyze the interpretation now under consideration as follows: (NR3) Action a treats (the humanity in) person P as a mere means if and only if a cannot bring about its end without affecting P, and there is some true description of a under which it is impossible for P to agree to a (other than the description “P did not actually agree to a”). The latter clause in the analysans (before the parenthesis) is intended to circumvent a kind of problem of relevant description. A theft can also be truly described as an “appropriation”; a rape is also an act of sexual intercourse. And there is no contradiction involved in a person’s agreeing to another’s appropriation of her property or to sexual intercourse. By specifying that “there is some description of a under which it is impossible for P to agree to a,” (NR3) ensures that an action cannot fulfill the Humanity Formula’s negative requirement merely through redescription. (NR3) properly deems actions such as theft or rape treatment as a mere means, because it is impossible for the victim of such an action to agree to it without undermining the action’s status as a theft or rape. Yet (NR3) results in false positives. Suppose a self-disrespecting wife agrees to her husband’s abuse of her, which he engages in for the end of venting his frustrations. Given her actual agreement to this treatment, I see no true description of it under which it is impossible for her to agree to it. Therefore, by (NR3), the husband does not treat his wife as a mere 21 Op. cit., p. 139. 22 Onora O’Neill, “Universal Laws and Ends in Themselves,” in her Constructions of Reason: Explorations of Kant’s Practical Philosophy (Cambridge: Cambridge University Press, 1989), pp. 138-39. 14 means. In reality, however, he clearly does. The same problem will attend any immoral treatment of one person by another where the object of the treatment agrees to be so treated. My argument has been an argument by elimination, with the twist that I claim to have eliminated all the alternatives. None of three reviewed understandings of the Humanity Formula’s negative requirement, I have contended, renders this requirement a tenable moral principle. And if this entailment of the Humanity Formula is untenable, then so must be the Humanity Formula itself. The potential pitfall of this argument is one that attends any argument by elimination: the best alternative might have gone unconsidered. Or perhaps a construal of the positive requirement can be offered that overcomes my objection that it lacks a criterion of permissible ends; this would obviate any need for the negative requirement. I would be happy if either of these lines of response to my critique turned out to be correct. It would be no small consolation to think that, in the countless hours I have spent poring over Kant’s excogitations about humanity as an end in itself, I was imbibing truth. After all, it’s something of a stretch to maintain that reading Kant is valuable for its own sake. 15