Virginia Held argues that terrorism can be justified in some instances. But unlike standard, consequentialist justifications, hers is deontological. This paper critically examines her argument. It explores how the values of fairness, responsibility, and desert can serve to justify acts of terrorism. In doing so, two interpretations of her account are considered: a responsibility-insensitive and a responsibility-sensitive interpretation. On the first, her argument collapses into a consequentialist justification. On the second, it relies on an implausible conception of responsibility. Either way, (...) her argument fails as a distinctly deontological defense of terrorism. (shrink)