My view, then, is not that which it has often been taken to be in discussion and which Singer, Regan, Clark, and others blast in their work; I am not suggesting that, because they lack language, animals can be factory farmed without suffering. Animals can suffer, which they could not unless they were conscious; so they are conscious. Nothing I have said in earlier chapters and nothing I will say in subsequent chapters is intended to deny this fact, which animal rightists correctly insist upon. But animals lack that reflective awareness which enables us to see our experiences and acts as our own (and thereby, of course, unlike animals, to be responsible for our acts).
(R. G. Frey, Interests and Rights: The Case Against Animals [Oxford: Clarendon Press, 1980], 109 [italics in original; footnote omitted])
Note from KBJ: Who thinks, much less argues, that animals are responsible for their acts? Animals are moral patients, but not moral agents. Like children, they can be wronged but cannot wrong. Nor does it follow from the fact that animals are not moral agents that they cannot have rights. There are two types of rights: autonomy-rights and welfare-rights. You and I have both. Animals have only welfare-rights, the most important of which is the right not to be made to suffer.