 The orthodox view regarding the formerly competent faces deeper challenges. In giving priority to Advance Directives and Substituted Judgment, the orthodox view overlooks the possibility that the earlier competent self and the current incompetent self may have conflicting interests. Advance Directives and Substituted Judgment are best suited for the contexts for which they were first developed in the law — conditions involving loss of consciousness such as persistent vegetative state — where the patient in the current incompetent state cannot have interests potentially different from the interests of the person he used to be. However, loss of decision-making capacity often comes about in less drastic, yet permanent conditions, which can leave the current incompetent patient with what seem to be powerful new interests in his new phase of life. Classic cases of this sort occur in Alzheimer's disease, other forms of dementia, and stroke. Before the loss of capacity, typically, the patient had numerous interests associated with his rich mental life and with a correspondingly complex set of values. Once mental deterioration progresses, the patient's universe of interests shrinks and new interests may become dominant. Sometimes the two sets of interests can come into conflict. Imagine, for example, a fully competent patient who, in anticipation of developing Alzheimer's disease, espouses a strong conviction, perhaps documented in an advance directive, that she does not wish to have her life prolonged in a demented state. She deeply identifies with her intellect, and thus views life with dementia as terribly degrading. But once she develops dementia, her identification with her intellect drops out as a concern, so she loses the corresponding desire not to prolong her life. In the meantime, she is still capable of simple enjoyments — she likes gardening or listening to music — and perhaps can even carry on meaningful human attachments. Her current, truncated set of interests does seem to favor continued life. Such scenarios raise difficult questions of how the interests of the earlier and current self ought to be balanced in surrogate decision-making. Privileging advance directives and recreating the judgment of the earlier self via substituted judgment are no longer the obvious solutions, given this conflict.