The first thing that will be examined is the theory of virtue ethics. Virtue ethics is not governed by action or law, but is guided within an individual's morality. Virtue ethics as a whole follows a vague baseline of what is considered right or wrong, but ultimately rests on the shoulders of the individual. Unlike some views of deontologists, virtue ethics does not seek to impose the right moral choice regarding an issue on others. As author Mary Ann Warren describes in her justification for when to classify a fetus as a person based on multiple criteria will include all entities requiring personhood. One of the major flaws found in Noonan's argument is his sole criterion for conferring personhood and refuting any other means of providing the criteria. This defect is one where a fetus may develop and have no biological ability to behave like a normal human being, such as a fetus that developed without certain organs needed to survive or thrive. From a virtue ethics perspective, it is generally wrong to continue to make a person suffer needlessly. If an individual lacks the ability to apply moral judgments due to lack of a brain and does not survive without the intervention of other people, the affirmation of the unique criterion of having two human parents is