tion. Also, regardless of the orthotic benefit of FES, the process of ‘‘learning-relearning’’ could vary from one individual to another depending upon the person’s inherent ability, and the type of neurological disorder and its severity. In general, this hypothesis therefore explains why individual might have short-lasting effect or no overall significant ‘carry-over’ effect. Our ‘‘learned paralysis’’ hypothesis of ‘carry-over’ effect contributes what may be an important link to understand the mechanisms by which FES induces a therapeutic effect. Further research to evaluate the effects of electrical stimulation therapy in stroke patients—particularly in the area of motor relearning and carry-over phenomenon—is justified and should continue.