According to Alasdair Cochrane, liberty can have value for most animals only because it allows them to obtain other desirable things, such as well-being. With this he concludes that humans can continue to use other animals as long as they treat them well. In this article, I reject this conclusion by arguing against the positive conception of liberty in favor of its negative or republican conception. I suggest that it is sufficient for a being to be capable of agency in order to have an interest in liberty, which deserves to be protected by the right to be free.