Two accounts explain why studying pictures reduces false memories within the Deese-Roediger-McDermott paradigm (J. Deese, 1959; H. L. Roediger & K. B. McDermott, 1995). The impoverished relational-encoding account suggests that studying pictures interferes with the encoding of relational information, which is the primary basis for false memories in this paradigm. Alternatively, the distinctiveness heuristic assumes that critical lures are actively withheld by the use of a retrieval strategy. When participants were given inclusion recall instructions to report studied items as well as related items, they still reported critical lures less often after picture encoding than they did after word encoding. As the impoverished relational-encoding account suggests, critical lures appear less likely to come to mind after picture encoding than they do after word encoding. However, the results from a postrecall recognition test provide evidence in favor of the distinctiveness heuristic.