For Tierney, however, seemingly any biomedical research is unethical; all studies for Tierney are "experiments" (however observational their methods), and all "experiments" that do not directly benefit the community involved in the study are "criminal" (p. 43). Thus James Neel, a recently deceased distinguished human geneticist as well as physician, who carried out an extensive series of biomedical studies of the Yanomami, is criminalized.