Rispoli (1998) presents data to motivate a model of pronoun case errors in child English. His data consist of relative rates of occurrence of errors involving particular forms in the study of twenty-seven English children between the ages of 2;6 and 4;0. I show that his claim that overextensions of he and him are antagonistic cannot be maintained. I argue that his explanation for why her subjects are more frequent than other errors is insufficient, and suggest an account in terms of relative input frequencies. Finally, I demonstrate that the fundamental assumption underlying Rispoliʼs model is untenable, and that his findings are not counterevidence for developmental syntax models such as that of Schütze (1997).