Brain-injured patients may frequently develop behaviour disorders in order to avoid participating in rehabilitation activities. In recent years, the use of behaviour modification techniques, particularly the use of positive reinforcement and time-out, has been increasingly reported in the literature as a means of remediating behaviour disturbance in this population. However, reward- or extinction-based programmes are generally not effective in the treatment of avoidance behaviours as they may be ineffective or, at worst, encourage further avoidance of rehabilitation activities. This paper, describes the use of satiation through negative practice in the successful treatment of a severely brain-injured patient whose behaviour, in the form of prolonged shouting, had previously not responded to the range of behavioural techniques used previously with this population. Two successive treatment programmes that were used in an attempt to satiate shouting are presented. Significant reductions in both the frequency and duration of shouting were found, enabling physical and functional gains to be made through successful participation in previously avoided rehabilitation activities. The validity of the use of this technique in the treatment of avoidance behaviour in brain-injured patients is discussed.