Noncontingent reinforcement (NCR) is typically implemented with extinction (EXT) for destructive behavior reinforced by social consequences and without EXT for destructive behavior reinforced by sensory consequences. Behavioral momentum theory (BMT) predicts that responding will be more persistent, and treatment relapse in the form of response resurgence more likely, when NCR is implemented without EXT due to the greater overall rate of reinforcement associated with this intervention. We used an analogue arrangement to test these predictions of BMT by comparing NCR implemented with and without EXT. For two of three participants, we observed more immediate reductions in responding during NCR without EXT. However, for all participants, NCR without EXT produced greater resurgence than NCR with EXT when we discontinued all reinforcers during an EXT Only phase, although there was variability in response patterns across and within participants. Implications for treatment of destructive behavior using NCR are discussed.