Shand (Cognitive Psychology, 1982, 14, 1-12) hypothesized that strong reliance on a phonetic code by hearing individuals in short-term memory situations reflects their primary language experience. As support for this proposal, Shand reported an experiment in which deaf signers' recall of lists of printed English words was poorer when the American Sign Language translations of those words were structurally similar than when they were structurally unrelated. He interpreted this result as evidence that the deaf subjects were recoding the printed words into sign, reflecting their primary language experience. This primary language interpretation is challenged in the present article first by an experiment in which a group of hearing subjects showed a similar recall pattern on Shand's lists of words, and second by a review of the literature on short-term memory studies with deaf subjects. The literature survey reveals that whether or not deaf signers recode into sign depends on a variety of task and subject factors, and that, contrary to the primary language hypothesis, deaf signers may recode into a phonetic code in Short-term recall. © 1990.