Woman thinking

Why Atheism?

The Big Questions, as their name implies, are questions about who we are, about the universe we live in, about our place in the universe, and more along these lines. Theistic religions, especially those that proselytize, have constructed cases for their beliefs that tend to pay a great deal of attention to these Big Questions. Sometimes widespread and culturally dominant religions even succeed in defining the terms of the questions, so as to give themselves greater assurance of their influence on the lives of their adherents and the societies in which they thrive. So far, we have considered why we are here, what happens after we die, why we should be good, and what the nature of truth is. From here, we move on to considering atheism itself and the reasons for believing it.

Setting out a case for atheism or a case for theism is a more personal endeavor than it may at first seem. Some such cases, because they are personal to their author, give an impression of close-minded certitude, of preaching to the choir, or of delivering a sales pitch. I hope this essay is free of those impressions, but I also hope you will indulge it fairly. It’s only natural to adopt a confident stance when defending a position one personally holds. This often makes for more interesting reading than insecure or highly uncommitted writings do, yet it can consequently come across as hubris. On the other hand, the moment an author permits some small room for doubt in their argument, some readers may check out and guard themselves with the thinnest of possible alternatives. We should be wary both of overestimating and underestimating the claims that confront us.

The question this essay addresses is not exactly why you should become an atheist, but is closer to addressing why I am an atheist. As such, the arguments featured here will be a selection, not an exhaustive survey. Of course, I would like to think some of the reasons that I give will be persuasive to others, and yet I do not believe a good argument must convince every rational person presented with it in order to be good. My aim is primarily to show that the case for atheism has some strong arguments, and that atheism is a reasonable position for one to hold. Although this article will not discuss the case for theism by point of contrast, there are several other articles covering the philosophical arguments for God that are available for perusal.

I. Atheism Defined

What is atheism, if we’re to go looking for arguments in its favor? It is common in some atheist circles to define atheism as a mere lack of belief in gods. This was my own approach for a number of years, and it is typically premised on the Greek word atheos, meaning ‘without God’. Etymology is not what determines the meaning of words, however, since words change and evolve over time through usage. Nor is it particularly useful to note that many atheists do understand atheism as an absence of belief when this definition runs into further troubles.

Theism and atheism are quite clearly at odds with one another. If theism is true, atheism is false, and if atheism is true, then theism is false. This sounds intuitive and is supported by the kinds of arguments against theism that have been put forward by atheists for centuries. Yet if to be an atheist is just to lack belief in gods, this opposition between theism and atheism becomes hard to explain, as atheism is no longer something capable of being either true or false. Unless atheism is propositional, like theism, it is difficult to imagine what sorts of justifying reasons could even be given for being an atheist. There are also those who call themselves agnostics and non-theists out of a conviction that the question of God’s existence is truly indeterminate. These folks do lack belief in God, but as they have judged the arguments against God to be unpersuasive too, it would not seem right to label them atheists.

Atheism, as philosopher Kai Nielsen puts it, is “a critique and a denial of the central metaphysical belief-systems of salvation involving a belief in God or spiritual beings”.1 This definition coheres well with that offered by J.J.C. Smart in the entry on atheism and agnosticism for the Stanford Encyclopedia of Philosophy: “‘Atheism’ means the negation of theism, the denial of the existence of God.”2 Finally, J.L. Schellenberg sums things up nicely,

God: (in some sense) necessarily existing creator of all things, omnipotent, omniscient, omnibenevolent, and loving. Theism: the claim that there is such a being. Atheism: the claim that there is no such being. The theist is commonly regarded as one who believes theism; the atheist believes atheism.3

The idea that atheism is any kind of belief is liable to upset some atheists who have heard one too many times that they are no different from, perhaps even worse than, religious believers when it comes to faith and dogmatism. This is an understandable frustration, although it really isn’t a good argument for redefining atheism. The distinguishing difference between theists and atheists should be less about the presence of belief and more about the content of belief. Some may say atheism is no more a belief than it is to doubt the existence of unicorns, fairies, or leprechauns, but for the reasons already given, I don’t think this assertion has much force.

Now that we understand atheism to be the negation or denial of theism, can we imagine that there are valid ways of arguing for atheism? On occasion, it has been claimed that proving a negative cannot be done, and that such a feat would require the atheist to be as all-knowing as God. However, proving a negative is done all the time, and does not demand any omniscience. One such means is by presenting evidence of absence. Christian philosophers William Lane Craig and J.P. Moreland explain that “the absence of evidence is evidence of absence only in cases which, were the postulated entity to exist, we should expect to have some evidence of its existence.”4 Another way of proving a negative would be to show that something leads to logical contradictions, and therefore cannot exist anymore than married bachelors or square circles exist. Although proving a negative can sometimes be an arduous task, it is not impossible, nor should it be special reason to criticize atheism when theism itself relies on a number of negative existential statements (i.e. the god of the ontological argument is a being than which no greater can exist).

This shows that atheism as defined here is not at a loss for justifying itself. With that, we will move on to the arguments.

II. Divine Hiddenness

“Ask and it will be given to you,” Matthew 7:7 reads, “seek and you will find; knock and the door will be opened to you.” Many theists believe that those who honestly seek after God will find God, but there have been and still are lots of nonbelievers in our world whose diligent searches have not led them to faith. There are those who have walked away from religion, who have never been religious, who have been lifelong seekers, and yet say that they would like there to be a god, and state that they are open to changing their minds. Paul claims in Romans 1:18-20 that God has made himself plainly known to everyone, but there are scores of men and women who are just as convinced that God’s existence is not obvious. Even the author of Isaiah admits this in saying, “Truly you are a God who has been hiding himself” (45:15).

J.L. Schellenberg helped to introduce the argument from divine hiddenness into academic discourse. On the subject, he writes

Possessed of perfect love and unconstrained by the limitations of finitude, a personal God would ensure that anyone capable of meaningful, conscious relationship with the Divine and not resistant to it was always in a position to enter into such relationship at some level. Now, this cannot be the case unless all creatures who are capable and nonresistant always believe in the existence of God, for such belief is a necessary condition of being in the position just described… Hence the fact that there are instead, and always have been, many nonresistant nonbelievers is an indication that there is no God.5

If God exists, it seems that he would want us to know he exists, particularly if he is the loving being many religions consider him to be. In the New Testament, this is supported by passages like 1 Timothy 2:3-4, which declare that God wants “all people” to be saved. Especially during times of tragedy and distress, we might expect that a Divine Father or loving God would reach out to console us, and although many who already believe would say this has been their experience, it has not been the experience of countless others. The psalmist reveals in Psalm 22:2 that even the faithful sometimes feel this absence: “My God, I cry out by day, but you do not answer.” There appears good reason to think that the silence or hiddenness of God is difficult to explain on theism, and makes better sense if atheism is true.

Theists have made several attempts at explaining hiddenness without conceding to atheism. Daniel Howard-Snyder suggests that the nonresistant nonbeliever may be nonresistant for the wrong reasons, such as a fear of punishment or fear of parental/social disapproval, and this could be reason for God to allow them to persist in nonbelief.6 Similarly, M.J. Murray argues that it might infringe on a nonbeliever’s autonomy and freedom for God to bring them to belief now.7 Responses like these are usually taken to be better as part of a cumulative explanation, since no single response probably is true of all nonresistant nonbelievers. Nonetheless, collectively or individually, these suggestions presume that the goods they describe are greater than the good of a personal relationship with God. Moreover, it seems that developing those goods could be a part of said relationship.

As I briefly note in my article on divine hiddenness, philosopher Stephen Maitzen has observed that the demographics of theism constitutes an additional problem. The distribution of believers and nonbelievers throughout the planet poses difficulties for ascribing theistic explanations to nonbelief, because, for example, there is no seemingly inherent reason for why Cambodians should be much less religious than Afghans. If God were remaining silent out of respect for our free will or any other reason, we should reasonably expect belief and nonbelief to be more even in their geographical distribution. For this and the other reasons mentioned above, the argument from divine hiddenness seems a strong instrument in the atheist’s case.

III. Minds Depend on Brains

Religious believers have claimed for centuries that the mind is separate from the brain. The part of us that does the thinking and houses our personality, typically referred to as the mind, is associated with concepts like the soul and the afterlife in many religions. According to this dualistic view, the brain is like the radio receiver picking up signals from the transmitter of the mind. Some believe that out-of-body and near-death experiences are proof the mind is distinct from the brain. A mind that somehow sustains itself with no need of a brain would certainly be cause for further investigation, and would raise suspicions about a non-physical realm of existence. In fact, this is one way God is often conceived of, as a disembodied mind.

However, there is good evidence to suggest that minds are dependent on brains. Dr. Michael Tooley lays out five points in defense of the argument, which are as follows:

First, when an individual’s brain is put into a certain physical state by direct stimulation, this causes the individual to have a corresponding experience, or, more generally, to be in some corresponding mental state.

Secondly, certain types of damage to the brain make it impossible for one to enjoy any mental states at all – either temporarily or permanently, depending on the nature of the damage.

Thirdly, damage to the brain destroys various mental capacities, and which capacity is affected depends upon the particular region of the brain where it was damaged.

Fourthly, the mental capacities possessed by animals of other species become increasingly complex and impressive as the brain becomes more complex.

Fifthly, in the case of individuals belonging to a single species, the development of mental capacities is correlated with the development of neuronal circuitry in the relevant regions of the brain.8

Neurologists can stimulate the brain in ways that evoke various experiences, even those of a religious nature.9 Traumatic brain injury can produce drastic changes in personality, and can also impair language, memory, thought processing, and other mental functions.10 If brain injury is serious enough, mental capacities may be lost altogether, sometimes resulting in a permanent vegetative state. These physical correlations are not just present in human beings, but are in other animal species as well. Animals with more complex brains (complex in the development of neurons) show signs of more complex behavior.11

In the article on what happens after we die, we looked at many of the concerns with out-of-body and near-death experiences. These experiences can be explained as the body’s way of calming us down and inducing a euphoric sensation to help us cope with significant injuries or with ‘equipment’ failures, but there are so many flaws and assumptions behind these stories that they can hardly be counted as evidence for mind-brain dualism or life after death. Arguments for God on the basis of consciousness will also not be relevant to this argument because it is specifically the embodiment of consciousness, and not its mere existence, that is on the table.

Of course, there are some theists who reject dualism just as most atheists do. The dependence of our minds on our brains does not rule out the possibility that God’s mind is an exception, but neither does admitting this spell defeat, since this is an evidential argument. Indeed, God could have reasons for making our minds reliant on brains, such as to highlight our finitude, yet we might just as easily imagine reasons why God would be a dualist. Either way, we are still faced with the question of whether theism or atheism best explains the evidence, and this is another instance where I think theism’s case is weak.

IV. Pain and Pleasure

Human beings have evolved a number of biological systems that prove useful in our survival and reproduction. Among these is the physical pain and pleasure system. The pain we experience when, for example, touching a hot stove is a warning to us and tells us that we are at risk of injury. Pain can help us recognize when our survival is at stake, before it is too late, so that we can act accordingly. Pleasure, on the other hand, can be a sign that something is biologically beneficial to us. We derive pleasure from sexual intercourse because of the role it plays in reproduction. Morally, though, pain and pleasure appear randomly distributed.

Philosopher Paul Draper identifies three facts from this picture that are peculiar given theism. They are, as he lists them:

(1) moral agents experiencing pain or pleasure we know to be biologically useful,
(2) sentient beings that are not moral agents experiencing pain or pleasure that we know to be biologically useful, and
(3) sentient beings experiencing pain or pleasure that we do not know to be biologically useful.12

If God exists, Draper claims, we could reasonably expect him to use the pain and pleasure system he has created us with in ways that are not biologically useful, but are goal-directed in a moral sense or in some other sense. If theism is true, it is surprising that we experience pleasure and pain as contributing to biological ends, not moral or salvific ends. On the alternative, however, the hypothesis of indifference (HI), this is quite expected. Pain and pleasure are not given by any benevolent being – they are simply one biological system among many.

As the second fact states, some sentient beings like young children and nonhuman animals are not known to be moral agents, though they nevertheless experience pain and pleasure the same as moral agents do. Again, this is unremarkable on HI because pain and pleasure just play a biological role, so whether or not an organism is a moral agent is irrelevant. But if there is a God, it is puzzling why he would subject non-moral agents to pain. On (1), it at least is plausible that God allows that pain for some moral purpose in the lives of those who experience it. The same cannot be said of (2) when the beings that experience pain are not moral agents. In his 1979 paper on the problem of evil, William Rowe presents the scenario of a fawn that becomes trapped and horribly burned in a forest fire, suffering for several days before dying.13 What part does the fawn’s torment play in the divine plan?

Fact three relates to instances where pain and pleasure do not seem to aid in survival or reproduction. Many have suffered agonizing deaths from terminal illness. Innumerable people have died in natural disasters that could not have been avoided. Some sadistic and psychopathic individuals may experience pleasure in causing others tremendous pain. In none of these instances does pain or pleasure apparently serve a biological function. Rather, it almost looks as if these experiences occur just because the pain and pleasure system we’ve all evolved is not ‘intelligently designed’ enough to adapt or to weed out cases of gratuitous suffering. Like the other facts, this one is better explained by HI than by theism, since a perfectly good God would have both the ability and the motive to give greater balance to the moral and biological components of pain and pleasure.

Responding to Draper’s argument, the theist may contend that because God desires that we freely choose the good, he has decided not to be so ‘obvious’ as to reflect moral or salvific ends through pain and pleasure. This objection faces the same problem as we saw above when it was used against the hiddenness argument, since it is not clear why free will would be a greater good than preventing certain instances of terrible pain. Additionally, one might well wonder just how effectively God is achieving his desire when pain can often cause people to venture down the wrong path instead of the right one. Another popular response, that of skeptical theism, claims we are not really in a position to know what all God knows, but the other side of this coin is that we then have no real basis for thinking God knows anything more that would explain why he permits the three facts mentioned. The biological role of pain and pleasure, it seems, makes a solid defense of atheism.

V. The History of Science

The historical track record of science seems to suggest something to us. Multiple varieties of supernatural explanation have been supplanted by naturalistic explanation, yet the converse has been woefully absent. Over the centuries, science has demoted God from numerous positions, such as making rain and lightning to sustaining the planets and fostering the diversity of life on Earth. The theist may still contend that God is the man behind the curtain, quietly controlling everything, but this curtain has been reduced to a washcloth by the advancement of naturalistic explanations. At this point in history, even many theistic scientists seem to agree that supernatural scientific hypotheses are less plausible than, and less preferable to, naturalistic ones.14

A swift response from some theists would be that there are, in fact, successful supernatural explanations of scientific phenomena. Creationists in particular would uphold this claim, perhaps with the suggestion that these sorts of explanations have just been suppressed, which accounts for their apparent rarity. The problem with this response is that even if true, it would still fail to explain why naturalistic explanations should be, on the whole, much more common than supernatural explanations. There are ways of challenging creationist arguments, of course, arguments which are not convincing to large numbers of theistic scientists, as already noted, but Niall Shanks puts the issue most forcefully:

Time and time again, scientists have considered hypotheses about occult entities ranging from souls, to spirits, to occult magical powers, to astrological influences, to psychic powers, ESP, and so on. Time and time again such hypotheses have been rejected, not because of philosophical bias, but because when examined carefully there was not a shred of good evidence to support them. Scientists are allowed, like anyone else, to learn from experience… The experience is straightforward. We keep smacking into nature, whereas the denizens of the supernatural and paranormal realms somehow manage to elude careful analysis of data.15

What is surprising is not simply that so many supernatural explanations have proven unsuccessful, but that in a vast majority of cases, naturalistic explanations have taken their place. If theism were true, it would not be unusual if we had discovered no link between minds and brains, or no evidence for evolutionary descent with modification. Indeed, such views were assumed by many folks for quite some time, since it makes a kind of intuitive sense that, as the omnipotent creator, God would have a great assortment of different designs available to his choosing, including ones that are irreducible and suggestive of design. But this is not what science has found. The persistent failure of supernatural explanations and the longstanding success of naturalistic explanations are facts we would expect to observe if atheism is true.

To be sure, naturalism does not explain everything, and there may be some things for which naturalistic explanations don’t suffice. Suppositions like these seem a bit premature, though, and we are still left wondering why, if God and other supernatural beings exist, “science can completely ignore them and still explain so much.”16 In an oft-cited apocryphal story, Napoleon asked Laplace why his theory of the universe did not make reference to God, to which the scientist replied, “I have no need of that hypothesis.” Laplace’s words, true to him or not, have proven prophetic for the scientific enterprise, and call our attention to one more argument favoring atheism over theism.

VI. Incompatible Properties

Up to this point, we have been looking at arguments for atheism that take an evidential form. That is to say that they proceed to argue against the existence of a god by reference to some fact about the world that supposedly makes theism improbable. Other kinds of arguments take a logical form, which means they try to show God does not exist by showing that there is some contradiction with the concept of God itself. Arguments that claim to establish how two or more of God’s attributes are logically contradictory are known as incompatible-properties arguments. Philosopher Theodore Drange outlines several such arguments in his 1998 paper, “Incompatible-Properties Arguments: A Survey,” and the three examples I will give here come from that paper.17

According to classical theism, two of God’s attributes are that he is perfect and he is the creator of the universe. To be perfect is to be complete, to lack nothing essential, and wants and needs are suggestive of a kind of incompleteness. For a being to create the universe implies that it created the universe out of a want or need, and yet God is just the sort of being that should have no want or need. Making the world out of love may sound like a good and perfect reason, but this nevertheless seems to convey that there was something missing prior to creation, and that God wanted or needed to resolve the situation. If this argument is successful, then a perfect creator of the universe cannot exist.

Another argument pits divine transcendence against divine omnipresence. Somehow, God is purported to both exist outside of space and time, and to exist everywhere in space and time. This might also be thought of as an incompatibility between transcendence and immanence, since the apparent contradiction is in being simultaneously beyond the world and yet present in the world. One analogy that attempts to explain this is the Flatland analogy. Three-dimensional objects transcend Flatland, but also exist within the dimensions of Flatland. As Drange notes, however, this analogy is still restricted to talking about objects in space, and so it doesn’t really make a clear defense of transcendence where transcendence is understood as existing outside space. Additionally, the transcendence-omnipresence argument raises the problem of how a being outside space-time is able to act within space-time.

Lastly for this section, the incompatibility of God’s perfect justice and perfect mercy is perhaps one of the more common kinds of incompatible-properties arguments to hear. To be all-just is to treat “every offender with exactly the severity that he/she deserves”, whereas an all-merciful judge “treats every offender with less severity than he/she deserves.”18 Following from this, it is logically impossible for someone to be perfectly just and perfectly merciful, since it would entail treating every offender with both exactly, and less than, the severity they deserve. Some theists may charge that God is more selective in showing justice and mercy, but does this not then only make it less meaningful to call God perfectly just or perfectly merciful? It might make better sense to say in that case that God is neither one.

In my opinion, incompatible-properties arguments have some strong challenges and intuitions underlying them, but because of the complicated and often technical subjects they involve, it can be difficult to really engage with them. This is especially true when it is a simple matter for many theists to plead human fallibility or just defend another version of whatever divine attribute is supposed to be the problem. It can always be claimed that we are too finite to know of what we speak, or that the god described is not the real god, but these replies may neglect their own burden of proof, and with the amount of religious disagreement that exists, we might find we have other reasons for resisting objections that can appear a little too ‘quick and dirty.’

We do not want to make the mistake of underestimating an argument, whether it is a theistic or an atheistic one. Arguments like these over the attributes of God can serve as a nice supplement to a broader case for atheism, even if they are not entirely convincing on their own merits.

VII. Yes, But Why Atheism?

Some may feel that this article focuses too much on the intellectual reasons for atheism. After all, several of the world’s biggest religions not only offer an intellectual case for belief, but add in promises of an afterlife, cosmic purpose, an ultimate triumph of good, and so forth. Of course, atheists (as we’ve defined them) regard all these promises to be just as untrue as theism itself. This is not necessarily concluded out of any distaste for said beliefs, either. There are nonresistant nonbelievers, as the argument from hiddenness addresses, who are open to being shown wrong, and some of them might actually even want to be wrong. But as we’ve seen in this article and in the other articles of this series, there are numerous good reasons for questioning and doubting the promises and beliefs of traditional theism.

I have also tried to give some explanation along the way for why atheists should care, and do care, about certain things like morality, truth, and life on Earth. Atheism is a negation, but what motivates and inspires women and men to become atheists is usually not negative. Many atheists have drawn on the rich traditions of humanism and Stoicism, as Professor John Shook discusses in his book on The God Debates.19 In Freethinkers: A History of American Secularism, Susan Jacoby documents a range of causes taken up by atheists in the United States, such as women’s rights, civil rights, freedom of conscience, and other social and political reforms. The image of the angry, despondent, or immoral atheist – so diligently cultivated by some religious interest groups – could not be further from the truth in a lot of cases, and this mischaracterization has thankfully been dying out gradually over the last few decades.

Atheism is not a path to salvation, it is not a religion, and professing atheism in some corners of the globe may still result in dire consequences. Concerns like these may, in spite of the intellectual arguments for atheism, deter one from identifying as an atheist. The question of why a rational person might subscribe to atheism is going to be different from why you or I might (or might not) subscribe to atheism, like I noted at the start of this essay. I think the case against theism is robust enough that it significantly threatens the case for theism, and I have provided a few reasons for this view here. Taken with critiques of the standard arguments for God, the psychological and sociological research on religion, the critical scholarship on religious texts, and other lines of evidence, I believe there is an ample and reasonable basis for being an atheist in the 21st century.

 


For more on the theism-atheism debate, see any of the following resources:

Arguing About Gods by Graham Oppy.
Atheism: The Case Against God by George H. Smith.
God? A Debate Between a Christian and an Atheist by Walter Sinnott-Armstrong and William Lane Craig.
Theism and Explanation by Gregory Dawes.
The Miracle of Theism by J.L. Mackie.

Arguments for Atheism (Index) at Internet Infidels.
Arguments for Atheism at Philosophyofreligion.info.
Atheism at the Internet Encyclopedia of Philosophy.

 

Sources:

1. Kai Nielsen, Atheism & Philosophy (Prometheus: New York, 2005), p. 59.
2. J.J.C. Smart, Atheism and Agnosticism, Stanford Encyclopedia of Philosophy, last modified Aug. 8, 2011.
3. J.L. Schellenberg, Hiddenness Arguments for Atheism, JLSchellenberg.com, last accessed Dec. 29, 2016.
4. William Lane Craig and J.P. Moreland, Philosophical Foundations for a Christian Worldview (InterVarsity Press: Illinois, 2003), p. 157.
5. J.L. Schellenberg, “Divine Hiddenness,” in Paul Draper & Charles Talliaferro (eds.), A Companion to Philosophy of Religion, 2nd ed. (Wiley-Blackwell, 2010).
6. Daniel Howard-Snyder, “The Argument from Divine Hiddenness,” Canadian Journal of Philosophy 26, no. 4 (1996): 433–453.
7. M.J. Murray, “Deus Absconditus,” in Daniel Howard-Snyder & Paul Moser (eds.), Divine Hiddenness: New Essays (Cambridge: New York, 2002), 62-82.
8. Michael Tooley, A Classic Debate on the Existence of God: Dr. Tooley’s Opening Statement, LeaderU.com, last accessed Dec. 30, 2016.
9. Jack Hitt, This is Your Brain on God, Wired (Nov. 1, 1999), last accessed Dec. 30, 2016.
10. What are the Potential Effects of TBI?, Centers for Disease Control and Prevention, last modified May 23, 2016.
11. Stephen Fleming, Are Chimpanzees Self-Aware?, Psychology Today (Nov. 16, 2012), last accessed Dec. 30, 2016.
12. Paul Draper, “Pain and Pleasure: An Evidential Problem for Theists,” in Daniel Howard-Snyder (ed.), The Evidential Argument from Evil (Bloomington: Indiana University Press, 1996), p. 16.
13. William L. Rowe, “The Problem of Evil and Some Varieties of Atheism,” American Philosophical Quarterly 16 (1979): 337.
14. Francis S. Collins, The Language of God (Free Press: New York, 2006), p. 228: “Whether probing the structure of the atom, the nature of the cosmos, or the DNA sequence of the human genome, the scientific method is the only reliable way to seek out the truth of natural events.”
15. Niall Shanks, quoted in Gregory W. Dawes, Theism and Explanation (Routledge: New York, 2009), p. 13.
16. Paul Draper, “God, Science, and Naturalism,” in William J. Wainwright (ed.), The Oxford Handbook of Philosophy of Religion (Oxford: New York, 2005), p. 209.
17. Theodore M. Drange, “Incompatible-Properties Arguments: A Survey,” Philo 1, no. 2 (1998): 49-60.
18. Ibid, 59.
19. John R. Shook, The God Debates: A 21st Century Guide for Atheists and Believers (Wiley-Blackwell, 2010), p. 214.