There is an increasing need for counselors to understand the current American Counseling Association Code of Ethics (2014) as they relate to value-based conflicts. Such conflicts represent dilemmas between the counseling profession’s collective values as represented in the Code of Ethics and a counselor’s personal values. Court cases related to value-based conflicts in the counseling profession will be discussed. A specific model for ethical decision-making by Kocet and Herlihy (2014) will be presented and explored as a means to reconcile value-based conflicts in counseling.