The two experiments reported in this study demonstrated that, in contrast to Steinmetz and Battig's (1969) data, preschool children do not display Priority of Recall in Newly Learned Items (PRNI) in either conventional Free Recall Learning (FRL) or in FRL where serial position bias is controlled. This finding, coupled with Battig and Slaybaugh's (1969) report of PRNI in FRL of adults, strongly suggests a developmental strategy interpretation of PRNI which emphasizes that the strategy is in part due to exposure to experiences (e.g., school) encouraging its use. (Author)