This study: (1) examined assumptions made about development of second-language writing skills by the teaching profession, as reflected in the American Council on the Teaching of Foreign Languages (ACTFL) proficiency guidelines, and (2) investigated the relationship between those assumptions and actual skills development, as reflected in the work of competent English writers as they begin writing in Spanish. Subjects were students enrolled in three levels of Spanish instruction at a selective university. Writing samples written during class time (18 at the first level, 12 at the second level, 8 at the third level) were analyzed for general characteristics (quality of message, organization and style, and standards of language use) of the sets of samples at each level. The analysis provided evidence that there are clear distinctions in the writing products of students at various levels of foreign language study. However, this group of students did not appear to follow the developmental sequence implicit in the ACTFL proficiency guidelines when beginning to write Spanish but began by building on English language writing skills. Clear differences were also found in the sophistication and complexity of writing products at different levels of study. Implications for second-language writing theory are discussed. (Contains 70 references.) (MSE)