M. B. Miller and G. L. Wolford (1999) argued that the high false-alarm rate associated with critical lures in the Roediger-McDermott (H. L. Roediger & K. B. McDermott, 1995) paradigm results from a criterion shift and therefore does not reflect false memory. This conclusion, which is based on new data reported by Miller and Wolford, overlooks the fact that Roediger and McDermott's false-memory account is as compatible with the new findings as the criterion-shift account is. Furthermore, a consideration of prior work concerned with investigating the conditions under which participants are and are not inclined to adjust the decision criterion suggests that the criterion-shift account of false memory is unlikely to be correct.