Larson (1987) proposes, contra Bresnan and Grimshaw (1978), that free
relatives with ''missing'' Ps are NP-headed and undergo antecedent-con
tained deletion, and that adjectival/adverbial free relatives are ''fr
ee comparatives.'' Using data not previously considered, he argues for
a head analysis of wh-phrases in free relatives. I argue here, on the
basis of data from English, French, and German, that (i) Larson's arg
ument for the ''head analysis'' is invalid, (ii) free AP/AdvP construc
tions are relatives, not comparatives, (iii) free relatives of all cat
egories are headed by null categories, and (iv) in missing-P free rela
tives, the overt P and the wh-phrase form a constituent located in [Sp
ec, C'].