Cu precipitation strengthening was compared in steels after treatments with and without cold rolling. A 0.2% C steel containing up to 1.5% Cu was quenched and tempered. Cu precipitation took place during tempering and increased its yield strength (YS). Quenched and tempered samples were compared with samples where cold rolling was performed between quenching and tempering. They exhibited significantly different mechanical properties. In addition, Cu alloying influenced the properties of each group of samples in different ways. The quenched and tempered samples exhibited behavior that is typical of precipitation hardening. Cu caused yield strength to increase with tempering temperature and time. The cold rolling of martensite reduced the maximal Cu-related strengthening and also eliminated its time and temperature dependence.