Starting from the observation that the constraints on VP-ellipsis (VPE) closely match those on VP-topicalization (VPT), Johnson (2001) proposes a movement account for VPE: in order for a VP to be deleted, it must first undergo topicalization. We show that although this proposal is attractive, making VPE dependent on VPT is problematic because VPE and VPT are not distributionally equivalent. While VPT targets the left periphery and consequently is subject to constraints on movement, VPE is not so restricted. We outline some alternatives for capturing the observed parallelism in the licensing of VPT and VPE.