In “A Critique of UNOS Liver Allocation Policy,” I argued that the UNOS policy of placing acute liver failure patients (ALF patients) above chronic liver failure patients (CLF patients) on the transplant list fails to satisfy the principles of utility and justice that ostensibly guide UNOS allocation policy. Further, I argued that physician discretion in evaluating ALF and CLF patients should be expanded—not constrained. In response, Dr. Burdick attempts to justify the policy constraints on physician discretion on the strength of objective differences between ALF and CLF; as he puts it, “the distinction between acute liver failure and progression of chronic liver disease … is clear in the way brain death is.”