Certain researchers lay claim to focusing on client agency and offer examples of client agency in their work. However, research that focuses on client agency does so in very different ways. In the psychotherapy research literature, there are few reflections about the various ways in which client agency is constructed. This article offers such reflections. First, an existential definition of agency is introduced. Then, two general models that grasp aspects of agency are presented. Differences between them are highlighted. A new model is then presented that identifies six ways in which psychotherapy research constructs client agency. Central examples from the research literature are presented to describe the new model.