Robert Kane (editor of the "Oxford Handbook of Free Will") is a leading incompatibilist philosopher in favour of free will. Kane seeks to hold persons morally responsible for decisions that involved indeterminism in their process. Critics maintain that Kane fails to overcome the greatest challenge to such an endeavor: "the argument from luck". Namely, if a critical moral choice is a matter of luck (indeterminate quantum fluctuations), then on what grounds can we hold a person responsible for their final action? Moreover, even if we imagine that a person can make an act of will ahead of time, to make the "moral" action more probable in the upcoming critical moment, this act of 'willing' was itself a matter of luck.