Voluntary action is an anticipated goal-oriented movement. The concept of voluntary action arises in many areas of study, including cognitive psychology, operant conditioning, philosophy, neurology, criminology, and others. Additionally, voluntary action has various meanings depending on the context in which it is used. For example, operant psychology uses the term to refer to the actions that are modifiable by their consequences. A more cognitive account may refer to voluntary action as involving the identification of a desired outcome together with the action necessary to achieve that outcome. Voluntary action is often associated with consciousness and will. For example, Psychologist Charles Nuckolls holds that we control our voluntary behavior, and that it is not known how we come to plan what actions will be executed.[1] Many psychologists, notably Tolman, apply the concept of voluntary action to both animal and human behavior, raising the issue of animal consciousness and its role in voluntary action.[2]