  One approach to defining Intention is to use the counterfactual tools
developed to define Causality. Direct Intention is considered the highest level
of intent in the common law, and is a sufficient component for the most serious
crimes to be committed. Loosely defined it is the commission of actions to
bring about a desired or targeted outcome. Direct Intention is not always
necessary for the most serious category of crimes because society has also
found it necessary to develop a theory of intention around side-effects, known
as oblique intent or indirect intent. This is to prevent moral harms from going
unpunished which were not the aim of the actor, but were natural consequences
nevertheless. This paper uses a canonical example of a plane owner, planting a
bomb on their own plane in order to collect insurance, to illustrate how two
accounts of counterfactual intent do not conclude that murder of the plane's
passengers and crew were directly intended. We extend both frameworks to
include a definition of oblique intent developed in Ashton (2021)
