case the freedom of an innocent child is pitted against the freedom of the evil-doer, it is not clear why God would remain unresponsive and passive. Christopher Southgate asserts that a freewill defense cannot stand alone as sufficient to explain the abundance of situations where humans are deprived of freewill. It requires a secondary theory. Another criticism is that the potential for evil inherent in free will may be limited by means which do not impinge on that free will. God could accomplish this by making moral actions especially pleasurable, or evil action and suffering impossible by allowing free will but not allowing the ability to enact evil or impose suffering. Supporters of the free will explanation state that would then no longer be free will. Critics respond that this view seems to imply it would be similarly wrong to try to reduce suffering and evil in these ways, a position which few would advocate. Natural evil A third challenge to the free will defence is natural evil, evil which is the result of natural causes (e.g. a child suffering from a disease, mass casualties from a volcano). Criticism of natural evil posits that even if for some reason an all-powerful and all-benevolent God tolerated evil human actions in order to allow free will, such a God would not be expected to also tolerate natural evils because they have no apparent connection to free will. Patricia A. Williams says differentiating between moral and natural evil is common but, in her view, unjustified. "Because human beings and their choices are part of nature, all evils are natural". Advocates of the free will response propose various explanations of natural evils. Alvin Plantinga, references Augustine of Hippo, writing of the possibility that natural evils could be caused by supernatural beings such as Satan. Plantinga emphasizes that it is not necessary that this be true, it is only necessary that this possibility be compatible with the argument from freewill. There are those who respond that Plantinga's freewill response might address moral evil but not natural evil. Some scholars, such as David Griffin, state that free will, or the assumption of greater good through free will, does not apply to animals. In contrast, a few scholars, while accepting that "free will" applies in a human context, have posited an alternative "free creatures" defense, stating that animals too benefit from their physical freedom though that comes