Finite-amplitude Langmuir circulation in the form of rolls parallel to
the wind direction is shown to be subject to three-dimensional instab
ility under certain circumstances. Density stratification is not requi
red for instability to manifest. The preferred form of this secondary
instability appears to be traveling waves propagating in the direction
of the wind. These cause the rolls, and their surface windrows, to de
viate from the wind direction by a small angle for which estimates are
given. The results of the paper show the value of secondary stability
results for the design of numerical experiments to simulate Langmuir
circulation.