We show that there is a β-model of second-order arithmetic in which the choice scheme holds, but the dependent choice scheme fails for a Π 1 2 -assertion, confirming a conjecture of Stephen Simpson. We obtain as a corollary that the Reflection Principle, stating that every formula reflects to a transitive set, can fail in models of ZFC − . This work is a rediscovery by the first two authors of a result obtained by the third author in [Kan79].