abstract Michael Otsuka claims that it is impermissible to kill innocent threats because doing so is morally equivalent to killing bystanders. I show that Otsuka's argument conflates killing as a means with treating a person herself as a means. The killing of a person can be a means only if that person is instrumental in the threat to Victim's life. A permission to kill a person as a means will not permit killing bystanders. I also defend a permission to kill innocent threats against Otsuka's Trolley Cases. Otsuka depicts a person tied to an oncoming trolley as a bystander. I argue that such characters are threats whom Victim can permissibly kill.