  We study the question of whether spontaneous U(1)_R breaking can occur in
O'Raifeartaigh-type models of spontaneous supersymmetry breaking. We show that
in order for it to occur, there must be a field in the theory with R-charge
different from 0 or 2. We construct the simplest O'Raifeartaigh model with this
property, and we find that for a wide range of parameters, it has a meta-stable
vacuum where U(1)_R is spontaneously broken. This suggests that spontaneous
U(1)_R breaking actually occurs in generic O'Raifeartaigh models.
