The create SD elicits the performance of any behavior in a non-specific, non-repeat contingency and, as such, involves a choice response on the part of the animal. The goal of this study was to identify the influence of Reinforcement Theory, response class, and primacy and recency on the create responses of three Atlantic bottlenose dolphins (Tursiops truncatus). Two-months of training sessions (i.e. “Pre-Assessment”, PA), followed by create requests (i.e. “Create Assessment”, CA, n = 119), were recorded in double blind trials, and each behavior was identified by reinforcement frequency, type, magnitude, and response class. When asked to produce a behavior of their choice, the dolphins elected to produce behaviors predominantly associated with the CA context versus the PA, which demonstrates the effect of primacy versus recency on the choice response. Additionally, since a repeat was the only “incorrect” response in a series of repeated cues, the CA was associated with reinforcement on a high frequency and high magnitude, fixed, low ratio schedule (i.e. FR1), supporting the influence of Reinforcement Theory on the responses of the three subjects. Thus, the create response was, in part, explained by the learning theories examined, indicating that the animals’ choices were not arbitrary but influenced by learning.