This paper presents a heuristic model of judicial independence that illustrates how it is that changes in de facto judicial independence may occur, even in the absence of overt institutional changes in de jure protections. The model is illustrated by the marked decline in the independence of Venezuela's high court between 1998 and 2010, under President Hugo Chávez. Focusing on the trade-off that courts face between jurisprudential change and policy change, the paper demonstrates how courts – even those that closely mirror the executive branch's policy preferences – may enter into conflict with dominant executives, and find their judicial independence restricted by informal means.