[AccessD] SQL INSERT Question

I have a client who write a lot of his own stuff.  Right now he's trying to
insert into an Access table memo field using the following:
 
 DoCmd.RunSQL "INSERT INTO tEvictionCasesTemp1 ( UDCaseID, Note ) " & _
                 "SELECT " & RS(0) & ", '" & RS(10) & "'"
 
which generates the error: "Syntax error in INSERT INTO statement"
 
RA(n) are the fields in a recordset hooked to SQL database.  The fields
RS(0) and RS(10) contain god data (he checked) with no embedded quotes or
apostrophes. Although he says that he needs to be able to 


The target field Note is a memo field in the Access table. RS(0) has already
been successfully inserted into tEvictionCasesTemp1.
 
What might be causing the syntax error?
 
MTIA
 
Rocky