 Choice is short for “the ability to express or communicate one’s choice”, and it is the simplest and least mental element of capacity. Indeed, its simplicity and obviousness may explain why some authors do not include it. To see that such an ability is necessary one needs only to imagine a case where understanding, appreciation and reasoning are all intact, but where the subject has no way to express or communicate her intended decision. Unless a subject’s preferred choice can be expressed to others in some outward way, it is impossible to know their intended decision. This is not trivial, since some patients—for example stroke victims or some patients with Locked-In Syndrome—can have an active mental life and satisfy the first three conditions but are unable to express anything verbally or through gestures (e.g., blinking the eyes, lifting a finger, etc.). This is why Grisso &amp; Appelbaum (1998: 34–37) include it as one of the elements lack of which compromises capacity.