 A proposal for a sufficient condition for treating another merely as a means might invoke a notion of actual consent. Suppose an agent is using another, the proposal might go; he is using her merely as a means if she has not consented to his use of her (Nozick 1974: 30–31; Scanlon 2008: 107). This simple proposal faces immediate difficulties. To cite one, imagine that a gravely ill young man has arrived via ambulance at a hospital. If medical personnel give him a treatment to save his life, they are presumably treating him as a means. Yet the proposed sufficient condition implies, with questionable plausibility, that since he has not consented to the treatment, they are treating him merely as a means. A slightly more complex proposal would go like this: Suppose an agent is using another. He is using her merely as a means if she has dissented to his use of her. This proposal would be free from the implication that the medical personnel treat the patient merely as a means. Although the patient does not consent to the treatment—he is unconscious and cannot do so—neither does he dissent from it. One possible shortcoming of this new proposal is that it lacks sensitively to the context of the dissent. Suppose someone has made a contract with a photographer to serve as her model for an hour-long photo-shoot at a park. After fifteen minutes, he proclaims that he does not wish to work anymore. If the photographer shoots a picture of him leaving the park, does she treat him merely as a means? The proposed condition implies, perhaps implausibly, that she does.