Epstein et al. (2014b) suggest, based on the labeling analysis of Chomsky (2013), that there is no NS-specific halting constraint barring syntactic wh-movement from a criterial position, contra Rizzi (2014) and Epstein (1992); that wh-movement is allowed freely in narrow syntax but the ensuing ill-formedness is the result of violating a language-specific morpho-phonological, CI requirements. In this paper, I will argue that NS-specific criterial freezing is real, not a syntactic illusion as claimed in Epstein et al. (2014b), directly affecting both CI and SM interfaces; and show how a wh-in-situ language like Korean can serve as evidence for this claim. I will also show how the system that keeps both the criterial freezing constraint and Chomsky’s (2013) notion of labeling can treat scrambling, which would otherwise be problematic under Chomsky’s (2013) labeling system.