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Recently Curran et al. (2014) and Hamaker et al. (2015) proposed a way to separate within and between effects in cross-lagged panel model (CLPM) framework. Although many empirical studies have begun to employ their methods, the reliability of within estimates under several conditions are not fully investigated. In this study, we thus investigate the within estimates of fixed effect CLPM (FE-CLPM), random intercept CLPM (RI-CLPM), and latent curve model with structural residuals (LCM-SR), and whether they provide stable and precise within estimates in the presence of unobserved heterogeneity. Our simulation result shows that the coefficients of within estimates of RI-CLPM and LCM-SR are sensitive to the inclusion of time-invariant covariates and the presence of unobserved heterogeneity.