In his early work, Frankfurt conceives of the will as a set of hierarchically organized desires. I argue that the hierarchical model fails to provide an adequate account of free will because it does not render the will determinate. In Frankfurt’s later work, he contends that love establishes the boundaries of the will by giving rise to a volitional necessity. I take this to suggest that the notion of love is introduced, in part, to eliminate the problematic indeterminacy implied by the hierarchical model. However, I argue that the necessities of love may be understood in two importantly different ways, and on either interpretation of Frankfurt’s considered view, love does not provide the resources to account for the phenomenon of betrayal of love. I conclude that the introduction of love does not render the will determinate, and therefore fails to resolve a problem that beset the hierarchical model of the will.