Fox (1994) purports to determine the appropriateness of the normative data for the Logical Memory subtest of the Wechsler Memory Scale — Revised for individuals in litigation and suggests that “… many of these people would have been incorrectly diagnosed as having a neuropsychological problem that did not exist.” His data do not support such a conclusion, but rather appear simply to demonstrate that patients in litigation concerning potentially painful orthopedic and/or emotional injuries can, as a group, perform slightly below average levels on memory tests.