Justifications for punishment include retribution, deterrence, rehabilitation, and incapacitation. Such laws serve the valid penological goals of incapacitation and deterrence. They are designed to counter criminal recidivism by physical incapacitation via imprisonment. Orthostatic headaches can become chronic and disabling to the point of incapacitation. Smoke inhalation can therefore quickly lead to incapacitation and loss of consciousness. It is capable of causing immediate incapacitation. However in his absence, death, or mental incapacitation the wife would do so. First holmgangs probably ended on the death or incapacitation of one combatant. This is sometimes referred to as "psychological incapacitation". Rutherford explains that he owes his current incapacitation to an attack by an inmate. Pereboom contends that the analogy holds for incapacitation of dangerous criminals. This precedence was found to occur through both displacement and incapacitation. This type of bullet is designed to cause instant incapacitation. With Gregor's unexpected incapacitation, the family is deprived of their financial stability. Taking advantage of his incapacitation, the powerful Alcmaeonid family arranged for him to be prosecuted.