American legal scholar Steven M. Wise states that speciesism is a bias as arbitrary as any other. He cites the philosopher R.G. Frey (1941–2012), a leading animal rights critic, who wrote in 1983 that, if forced to choose between abandoning experiments on animals and allowing experiments on "marginal-case" humans, he would choose the latter, "not because I begin a monster and end up choosing the monstrous, but because I cannot think of anything at all compelling that cedes all human life of any quality greater value than animal life of any quality."