In a recent placebo-controlled comparison, behavioral activation was superior to cognitive therapy in the treatment of moderate to severely depressed adults. Moreover, a subset of patients exhibited a pattern of extreme nonresponse to cognitive therapy on self-reports of depression not evident on the clinician ratings. These patients were severely depressed, functionally impaired, and had primary support group problems; most also described themselves as having life-long depressions. Comparable numbers of patients with such characteristics were assigned to behavioral activation, indicating that randomization did not fail, and most instances occurred in the context of adequate cognitive therapy. If this pattern of self-reported extreme nonresponse to cognitive therapy replicates, it would suggest that there might be a subset of patients who see themselves as doing better with sustained attention to behavior change in time-limited treatment.