Previous research on VP-ellipsis has revealed the existence of a Mismatch Asymmetry, whereby cases with passive voice ellipsis clauses and active antecedent clauses are less acceptable than cases with active ellipsis clauses and passive antecedents. According to the memory-based explanation offered by the Recycling Hypothesis (RH; Arregui et al. 2006), this effect arises because passive clauses are more prone to be misremembered as active than the other way around, and hence passive-active mismatches are more likely to create an “illusion of grammaticality”. This paper describes three experiments that explore the source of the asymmetry, with particular attention to the predictions of the RH account on previously unexamined cases. The findings are inconsistent with the predictions of memory-based explanations such as the RH, and instead point to the existence of a penalty against passive ellipsis clauses in subject focus environments, one that applies to both matched and mismatched cases of VP-ellipsis and in both anaphoric and cataphoric discourse configurations. A possible explanation for the penalty is offered as a subject for future work.