In 2014, researchers in West Virginia found that recent model Volkswagen vehicles emitted up to 40 times the permitted levels of nitrogen oxides (2). These vehicles had special software that determined when the vehicle was in laboratory test conditions and the software then altered the vehicle's functionality to emit the legal amount of nitrogen oxides allowed by the EPA. The software has been found in about half a million vehicles in the United States. In addition to the bad publicity, the Volkswagen scandal will cost the company at least $15.3 billion in compensation to the owners of the affected vehicles (3). In 2016, Volkswagen engineer James Liang pleaded guilty to playing a crucial role in the development of the illegal software (3). The software was created because Volkswagen was unable to meet stringent EPA emissions standards. Therefore, a small team of engineers, including James Liang, decided to cheat emissions tests to allow the sale of Volkswagen vehicles. USKant's moral theory focuses on the intention of the action, rather than any consequences attached to that action. According to Kant, the will of the individual is what animates the individual's body, while duty is obedience to a moral law. An individual's will is considered strong when it is aligned with duty, even if the consequences harm that individual. For example, a student may fail a test instead of cheating because he believes that cheating is wrong. “You shouldn't cheat” is an example of a maxim, a subjective principle that governs action. For a maxim to be morally right, it must be a categorical imperative, carried by an individual to a universal scale. In other words, it is rationally possible... middle of paper... and consequences, as a utilitarian would. Although Liang's decision was immoral, he never treated anyone simply as "mere means." It could be argued that the people who purchased the affected vehicles were used as “mere means” to an end. Since Liang's decision, those customers are part of the consequences, so they are not considered. However, the Volkswagen company as a whole used customers as a “mere means” to an end, as it believed that a simple cash payment would be enough to make up for customer disappointment. According to Kant's moral theory, Liang's decision to create the illegal software to cheat the EPA's emissions tests was morally wrong, even if out of necessity. While it can be argued that it is also morally wrong from a utilitarian perspective, it is important to realize that both theories reached the same conclusion through different processes..