Substructure in galaxy clusters can be quantified with the robust a statist
ics (Dressler and Shectman 1988) which uses velocity kinematics and sky pro
jected positions. We test its sensitivity using dissipationless numerical s
imulations of cluster formation. As in recent observations, about 30% of th
e simulated clusters show substructure, but the exact percentage depends on
the chosen limit for defining substructure, and a better discriminator is
the distribution function of the Delta statistics. The Dressler-Shectman st
atistics correlate well with other subcluster indicators, but with large sc
atter due to its sensitivity to small infalling groups and projection effec
ts.