An acquired dysgraphic patient - BA - is described who produces a large proportion of nonword responses. It is shown that single letter substitutions tend to preserve consonant-vowel status and that the majority of errors are orthographically legal. It is shown that these constraints do not arise from an application of phoneme-to-grapheme conversion procedures, since these skills are severely impaired in BA. They also do not arise from frequency-sensitive bigram/trigram units since her responses do not contain bigrams/trigrams that are higher in frequency than the target. It is suggested that BA's results support the notion of consonant-vowel encoding and syllable-like units in orthography. They do not, however, support the notion that orthographic syllables can be ranked according to complexity since no effects of syllabic complexity were found. This latter finding is consistent with previous results reported in English-speaking dysgraphic patients.