In this study we show that constituency is of limited importance for a proper treatment of the interaction between the linear position of a wa-marked nominal in a Japanese sentence and possible domains of contrastive focus, and that constraints concerning contrastive focus should be represented in terms of linear order and not constituency. Linearisation HPSG, where linear order is independent from constituency, provides a good basis for an analysis. Some constraints are provided in terms of order domains, and it is shown that these constraints can deal with the phenomena in question, and that the cases problematic for the constituency-based analyses can also be accounted for by our analysis.