One could also be framed for a crime which had not in fact occurred. In 2267, Benjamin Finney framed James T. Kirk for his apparent "death" in order to get revenge on Kirk, whom Finney believed to be responsible for his not being promoted. (TOS: "Court Martial" ) Seska tried to mask her crimes aboard USS Voyager by mentioning Joe Carey. In her final sabotage aboard the ship, she used her own security code to blame Carey for this act. (VOY: "State of Flux")