William F. Baxter, a law professor who passed away in 1998, argued in People or Penguins: The Case for Maximum Pollution (1974) that the cost of a pollution-free society would be harmful to humans. He assumed that humanism requires that humans are what matter above all else. Baxter expressed a general critical view of environmentalism held by human beings who do not believe that animals have intrinsic worth or rights equal to those of humans.