Francione maintains that we have no moral justification for using nonhumans, arguing that because animals are property-economic commodities-laws or industry practices requiring "humane" treatment will, as a general matter, fail to provide any meaningful level of protection. Garner favors a version of animal rights that focuses on eliminating animal suffering and adopts a protectionist approach, maintaining that, although the traditional animal-welfare ethic is philosophically flawed, it can contribute strategically to the achievement of animal-rights ends.