Expansion or contraction of a volume of rock due to a rapid phase change has been proposed as a mechanism for the generation of earthquakes. This hypothesis, as applied to shallow focus earthquakes, is examined in the light of evidence from natural and experimental petrologic systems. Source volumes calculated for shallow focus earthquakes (focal depth = 15 km) are much larger than those calculated for deep focus (focal depth = 700 km) earthquakes. Large source volumes are shown to present several difficulties to the application of this hypothesis to shallow focus earthquakes.