 Other scholars hold what is called an “appropriation reading” (see Winkler 1991, Thiel 2011, LoLordo 2012). Under this reading, what Locke means when he says that sameness of person consists in sameness of consciousness, is that any person extends back only to those mental events or acts which they take to be their own. In other words, the persistence of any person or self is best seen in terms of the “subjective constitution of the self” (Winkler 1991: 204). There might be a worry that under this kind of reading, Locke gives persons too much authority. That is, a person could deny that she is the one who committed the crime, just because she doesn’t see that act as her own. But, although the “self has a certain authority over its own constitution”, Kenneth Winkler makes clear that 