The stresses involved in shallow earthquakes and their occurrence along fault planes suggest that they occur by failure on weak planes, rather than by brittle fracture of a homogeneous material. Possible orientations of the stress tensor are examined to determine what limits fault plane solutions can place on the orientation of the greatest principal stress. For the general case of a triaxial stress, the only restriction is that this stress direction must lie in the quadrant containing P, but may be at right angles to the P direction. Thus shallow earthquakes impose a few limitations on the orientation of the stress tensor. In contrast the fault plane solutions from deep earthquakes are best explained by fracture of a homogeneous material, with the greatest principal stress directed down the dip of the earthquake zone.