Keio Colloquium
9/5/2020
Handout①

Multiple Case Valuation and Its Implications
永盛貴一（明治学院大学・獨協大学）

Main claim
A nominal phrase can receive more than one Case
1. Multiple Case Valuation via Agree/Merge: General Introduction
1.1 Free Applications of Merge(1) Merge is the fundamental operation of the computational system of human language.
It is defined as a set-formation operation that takes two syntactic objects (SOs), α
and β, and forms a new SO, a two-membered set {α, β}.
(2) External Merge (EM) and Internal Merge (IM) are instantiations of the single
operation Merge. The single operation Merge, in its simplest form, is not triggered
but applies freely. (cf. Epstein, Kitahara, and Seely 2014, Chomsky 2013, 2015a).
1.2 Phases, PIC, and Transfer(3) I assume that phases include nP, vP, and CP and that the following condition holds.
Phase Impenetrability Condition (PIC):
In phase α with head H, the domain of H (i.e., the complement of the phase head)is not accessible to operations outside α, only H and its edge are accessible to suchoperations.
(Chomsky 2000: 108)
(4) Once a phase (XP) has been completed, the complement of the phase head (WP)
undergoes Transfer to the conceptual-intentional (CI) and sensorimotor (SM)interfaces.
XP
ei
YP ei
X0
WP

Transfer(5) I assume that Transfer is an operation that cyclically strips off the complement of
the phase head upon completion of a phase and sends it over to the interfaces (cf.
Chomsky 2000, 2008, Narita 2011, 2014, Takita et al. 2016).
1

1.3 Labeling and Minimal Search(6) Chomsky (2013, 2015a) assumes that Labeling Algorithm (LA) is just a minimal
search (as in Agree), applying as part of the Transfer operation.
(7) If an SO is of the form {H, XP}, LA selects H as the label. In contrast, if an SO isof the form {XP, YP}, LA is ambiguous, locating both the heads of XP and YP.
a. SO = {H, XP}
H
ei
H
ei
X

b. SO = {XP, YP}
??
wo
ei
ei
X
Y

(8) Chomsky (2013, 2015a) proposes that there are two ways in which the SO in (7b)can be labeled. One way is to raise either XP or YP so that there is only one visible
head. The other way is to share prominent features (i.e., ϕ or Q) via Agree (i.e.,
minimal search).
a. SO = {tXP, YP}

b. SO = {XP[F], YP[F]} ([F] = ϕ, Q)

Y(P)
wo
tXP
ei
Y

<F,F>
wo
ei
ei
X[F]
Y[F]

(9) However, as Tonoike (2014) and Takita et al. (2016) point out, the idea that thelower copy is invisible to LA (i.e., tXP in (8a)) is incompatible with the copy theoryof movement. Even after XP is raised in (8a), we still have the configuration (7b).
(10) Takita et al. (2016), following Narita (2011, 2014) and Goto (2013), propose thatin cases like (7b) Transfer (Spell-Out in their terminology) contributes to labeling,
as shown below (Angle brackets indicate copies).
a. I wonder which book Bob thinks John bought.
b. …[α <which book> [β C[-Q] [TP …]]]c.
α
wo<which book>
β
wp
C[-Q]
TP
…

(Takita et al. 2016: 185)(11) The label of α remains unlabeled because it is still an XP-YP configuration.
2However, Takita et al. (2016) argue that Transfer applies to TP and sends it to theinterfaces, making it possible for LA to detect C[-Q] as the label of α.
a.

α

b.

wp

<which book>

α
wp

β

<which book>

C[-Q]

wp

C[-Q]

TP

Transfer…

(Takita et al. 2016: 186)

(12) Transfer reduces the set {<which book>, {C[-Q], TP}} into the set {<which book>,{C[-Q]}}. Takita et al. (2016) assume, following Chomsky (2012), that a singleton
set is equivalent to its member. 1 Thus, the set {<which book>, {C[-Q]}} will be
regarded as the set {<which book>, C[-Q]}.
(13) Let us now consider another XP-YP configuration, namely subject-raising.
a.

α

b.

wo

<nP>

α
wo

β

<nP>

v

wo

v

VP
…

Transfer(14) The label of α remains unlabeled. However, Transfer reduces the set {<nP>, {v,VP}} into the set {<nP>, {v}}. Here again, if the singleton set {v} is equivalent
to its member v (cf. Chomsky 2012), the set {<nP>, {v}} will be regarded as theset {<nP>, v}. Then, LA can unambiguously detect v as the label of α.
(15) Let us now turn to the treatment of root elements (i.e., V and T). Chomsky (2013,2015a) assumes that V and T are unspecified (i.e., category-neutral) roots in thesense of Marantz (1997) and Borer (2005) and that they are too weak to serve aslabels.
(16) However, Chomsky (2013, 2015a) assumes that V can serve as a label if its “Spec”
position is filled by an element that bears features agreeing with it (i.e.,“strengthening” in Chomsky’s terminology).
Mathematically speaking, this is not correct because the set of the empty set {Ø} is not equivalent
to the empty set Ø. But I follow Chomsky (2012) and assume that a singleton set is equivalent to its
member as far as linguistic structure is concerned. I would like to thank Naoki Fukui for pointing
this out.
13➢ Two problems:(i) The claim that V is universally too weak to serve as a label is nothing but astipulation, and should be avoided if possible (cf. Goto 2017).
(ii) If V is universally too weak to serve as a label unless its “Spec” position is filled
by an element that bears features agreeing with it, V in non-agreeing languages like
Japanese (cf. Fukui 1986, 1988), can never serve as a label since there is no way to“strengthen” the root element.
(17) Thus, I will depart from Chomsky (2013, 2015a) and assume instead, following
Abe (2016) and Kitahara (2017), that V can serve as a label on its own.
(18) Chomsky (2015a) assumes that T in English (i.e., poor-agreement languages) is
too weak to serve as a label unless its “Spec” position is filled by an element thatbears features agreeing with it, while T in Italian (i.e., rich-agreement languages)
is strong enough to serve as a label.
➢ Two problems:(i) The claim that T is strong or weak runs the risk of stipulation and should be
avoided if possible (cf. Goto 2017).
(ii) If T in poor-agreement languages is too weak to serve as a label unless its “Spec”
position is filled by an element that bears features agreeing with it, T in Japanese
can never serve as a label because Japanese lacks agreement features altogether (cf.
Fukui 1986, 1988).
(19) Thus, I will depart from Chomsky (2013, 2015a) and assume instead, following
Kitahara (2017), that T can label on its own.2
Assumptions:(i) T can label on its own.
(ii) V can label on its own.
1.4 Case Valuation via Agree/Merge(20) Chomsky (2013, 2015a,b) suggests that the Probe-Goal system should now be
reduced just to minimal search (finding the first head(s)). For instance, Chomsky(2015b) states:“The Probe is just… There isn’t any identifiable Probe. There is just a search
I will leave open the question of how to derive the differences between English and Italian. Goto
(2017) and Gallego (2017) attempt to derive the differences between the two types of languages
without recourse to the feature-strength parameter on T.
2

4

procedure, which is trying to find… It takes a look at a syntactic object and it’s
asking the question, “What are you?” Now you could formulate Agree that way. You
could say there is no Probe, it’s just that you’re searching for some unvalued feature,and then if you find it, you look for something that will be valued by its relations to
it. That’s the Probe-Goal relation. But they’re reduced both just to search.”(Chomsky 2015b: 81)(21) Chomsky (2015b) further states:“I don’t think we should take Probe-Goal too literally. In the case of tense andsubject, you can think of the tense as searching for the subject, but that’s kind ofanthropomorphic. It’s just that a relation exists, and it should be a minimal
computational relation, and that minimal relation values unvalued features –actually, in both ways, like the tense will get valuation of ϕ-features and the subject
will get Case.”(ibid.)(22) I will assume that Agree is reduced just to minimal search (finding the firsthead(s)) and that minimal relation values unvalued features (cf. Fukui and Narita
2012, Abe 2016, Fukui 2017, Kitahara 2017).
(23) I do not adopt the mechanism of feature inheritance (FI).3➢ Reasons:(i) FI is an operation quite different from the core operations of syntax such as
Merge and Agree/Search. It is a feature-depriving mechanism, which cannot be
reduced to anything.4(ii) As Kitahara (2017) states, unless compelled by empirical facts, simpler (iib)should be selected over more complex (iia).
a. C/v* bears uPhi inherently, and T/R inherits uPhi from C/v* derivationally.
b. T/R bears uPhi inherently.
(Kitahara 2017: 245)(24) I thus assume instead that (finite) T and V inherently bear unvalued ϕ-features (cf.
Fukui and Narita 2012).
(25) When an object nP undergoes “raising” into “SpecVP,” Agree, which is now
reduced to minimal search (applying from top-down and finding the first head(s)),
holds between [uϕ] of V and [vϕ] of the object nP (more precisely, [vϕ] of n), as
shown below (cf. Fukui and Narita 2012, Chomsky 2013, 2015a, Kitahara 2017).
Fukui and Narita (2012), Kato et al. (2014), Gallego (2014), and Kitahara (2017) develop systems
which do not adopt the mechanism of FI.
4
But note that Ouali (2008) proposes that C may keep a copy of the ϕ-features inherited by T.
3

5

<ϕ,ϕ>woru
run[vϕ][uCase] NP
V[uϕ] run[vϕ][uCase] NP(26) Minimal search (i.e., Agree) can find a pair of matched ϕ-features and the minimal
relation values unvalued features. Such an XP-YP configuration is the only one
where minimal search can find the two heads X and Y simultaneously (cf.
Kitahara 2017; see also Fukui and Narita 2012). As a result, [uϕ] of V gets valued
and [uCase] of n also gets valued (i.e., accusative).
(27) Let us now turn to subject-raising, where the subject nP moves up into “SpecTP,”
as illustrated below.
<ϕ,ϕ>
wo
ru
ru
n[vϕ][uCase] NP
T[uϕ] runP…
(28) Minimal search, applying from top-down and finding the first head(s), locates both[uϕ] of T and [vϕ] of n simultaneously. As a result, [uϕ] of T gets valued and[uCase] of n also gets valued (i.e., nominative).
(29) Let us now turn to the mechanism of Case valuation in Japanese. Japanese is alanguage which does not exhibit ϕ-feature agreement. I follow Fukui (1986, 1988)
in assuming that Japanese lacks ϕ-features in its lexicon (see also Kuroda 1988).
(30) Zushi (2014, 2016) proposes, drawing on some “classical” works such as Kuroda(1965, 1978, 1983, 1987, 1988), Saito (1982), and Fukui (1986, 1988), that Casevaluation in Japanese occurs through (External) Merge, a proposal that I adopt.
(31) Zushi (2014, 2016) argues that in Japanese, the unvalued Case feature of a nominal
phrase is valued by the following rules.
a. When a nominal is merged with a lexical head, its case feature is valued as
accusative.
b. When a nominal is merged with a phase head (v or n), its case feature is valued
as nominative or genitive.
c. Otherwise, the case feature of a nominal is valued as dative. (Zushi 2016: 48)
6

(32) For example, suppose the nominal phrase hon ‘book’ is merged with the lexical
head kak- ‘write’ to form the set {hon, kak-}. Upon completion of the vP phase,the complement (i.e., {hon, kak-}) undergoes Transfer. I assume that the unvalued
Case feature of hon ‘book’ is valued as accusative as part of Transfer.5
ei
ei
EA
ei
v
nP
V
Transfer(order irrelevant)(33) Let us then examine how nominative Case valuation takes place.
a.

ei
ei
nP
ei
v
IA
V
Transfer

b.

ei
v
nP

(34) In (33a), the nP is not merged with the head v. However, as Narita (2011, 2014),
Goto (2013), Takita et al. (2016) and Kobayashi (2017) argue, upon completionof the vP phase, Transfer strips off the complement of the phase head v, making it
possible for the nP to become a sister of v, as shown in (33b).
(35) Transfer reduces the set {nP, {v, VP}} into the set {nP, {v}}. Given the assumptionthat a singleton set is equivalent to its member (cf. Chomsky 2012), the set {nP,{v}} will be regarded as the set {nP, v}.
(36) Following Fukui (1986, 1988), I assume that Japanese lacks C in its lexicon. If so,
the remaining constituents in (33b) will undergo Transfer at the point of TP (i.e.,at the end of the overall derivation). Thus, when (33b) undergoes Transfer, LA
detects v as the label of the SO {nP, v} and nP is valued as nominative.
(37) This approach can be extended to multiple nominative sentences (cf. Kobayashi2017). The derivation of multiple nominative sentences looks like the following.6

5

I would like to thank Naoki Fukui and Takaomi Kato for helpful discussion on this point.

Fukui (2011) and Zushi (2014, 2016) assume that Japanese allows unbounded Merge to be applied to the edge ofa phase head, provided that the elements merged at the edge of a phase satisfy such a licensing condition as
predication to receive an appropriate interpretation.
7
6

a.

ru
ru nP1
VP
v

b.

ru
ru
nP2
v
nP1

…
Transfer

c. ru
v
nP2

Transferd. {nP1, {v, VP}}⇒{nP1, {v}}⇒{nP1, v}⇒{nP2, {nP1, v}}⇒{nP2, {v}}⇒{nP2, v}(38) In the multiple nominative construction, more than one nominative phrase ismerged at the edge positions of v (cf. Fukui 2011, Zushi 2014, 2016). In contrast,in the phenomena that I call multiple Case valuation, a single nominal phrase
receives more than one Case.
1.5 Multiple Case Valuation via Agree/Merge
1.5.1 Multiple Case Valuation via Agree(39) It is widely assumed that once Agree takes place between a “Probe” and a “Goal,”
the latter is soon inactivated for further ϕ-agreement and Case valuation.
Chomsky (2000, 2001, 2008) states this as the Inactivity Condition.
Inactivity Condition:
An A-chain becomes invisible to further computation when its uninterpretablefeatures are valued.
(Chomsky 2008: 150)
(40) However, given the empirical evidence for multiple Case valuation (cf. McCreight
1988, Bejar and Massam 1990, Yoon 1996, Svenonius 2005, Merchant 2006,
Narita 2007, Richards 2012, Pesetsky 2013, Levin 2017, Chen 2018), I will departfrom the Inactivity Condition and argue that even if the Case feature of a nominal
phrase has been valued via Agree, it can enter into further ϕ-agreement and Casevaluation as long as it is in narrow syntax.
(41) More specifically, I argue, following Bruening (2001) and Narita (2007), that
Agree only values the unvalued Case feature and that Transfer renders the nominal
phrase inactive for further ϕ-agreement and Case valuation.
(42) This implies that as long as the Case feature of a nominal phrase escapes Transfer(by moving to the edge of a phase) and is still in narrow syntax, it remains active
and retains its ability to receive another Case value via further Agree.
(43) That the Case-valued nominal phrase can undergo IM into the edge of a phase canbe illustrated by the derivation of the wh-question.
8

a. What did you buy?
b.

wowhat[vϕ][vCase] woyou
wo<ϕ,ϕ>v
wowhat[vϕ][uCase]woV[uϕ]what[vϕ][uCase](44) The wh-phrase what undergoes IM into the edge of v (on the way to the edge ofC) after it has received accusative Case (cf. Epstein, Kitahara, and Seely 2010,
Obata and Epstein 2008, 2011, 2012).
(45) As I argued above, if a nominal phrase escapes Transfer (by moving to the edgeof a phase) and remains in narrow syntax, it still remains active and retains theability to receive another Case value via further Agree. This implies that the Casevalued wh-phrase is still capable of receiving another Case value. There isevidence from Cuzco Quechua.7
Pi-qpa-ta-ni
muna-nki[ ti platanu ranti-mu-na-n-ta]
who-GEN-ACC-AF want-2
bananas buy-NML-3-ACC‘Who do you want to buy bananas?’(Lefebvre and Muysken 1988: 161)(46) In (45), pi ‘who’ receives genitive Case in the nominalized clause. But when it
undergoes IM into the higher clause, it receives accusative Case.
(47) I argue that not only wh-phrases but also non-wh-phrases (e.g., the book, John,etc.) can undergo IM into the edge of a phase even after it has received a Casevalue via Agree. If it undergoes IM into the edge of a phase at Transfer, it still
remains active and retains its ability to receive another Case value via further
Agree. I would like to refer to this as multiple Case valuation via Agree.8(48) The mechanics of multiple Case valuation via Agree can be schematically
Hungarian might also provide relevant evidence (cf. Bejar and Massam 1990).
(i) kiketi
mondtad hogy szeretnél
ha eljönnének t i
who-ACC you-said that you-would-like if came (3pl)‘Who did you say that you would like it if they came?’(Bejar and Massam 1999: 66; cited from Kiss 1985)
In (i), the wh-phrase originates in the finite if-clause, where it receives nominative Case. But when it moves up into
the higher clause, it receives accusative Case from the intermediate verb (cf. Obata and Epstein 2011).
Morphologically, it realizes the last Case value (i.e., accusative Case).
8Note that the system of multiple Case valuation via Agree that I am proposing here is different from the system
of multiple Agree proposed by Hiraiwa (2001, 2005). Under Hiraiwa’s (2001, 2005) theory, a single “Probe” agrees
with multiple “Goals” simultaneously. In contrast, under my theory, a single “Goal” agrees with multiple “Probes”
cyclically.
97

illustrated below.
Agree

Agree

H2[uϕ]…XP[vϕ][Case2]…H1[uϕ]…XP[vϕ][Case1]
Internal Merge(49) (i) H1 agrees with XP and the unvalued Case feature of XP gets valued.
(ii) XP undergoes IM into the edge of the phase head H1 at Transfer. (Agree only
values the unvalued Case feature of XP and the inactivation is suspended till the
point when it undergoes Transfer.)(iii) XP remains active and retains its ability to receive another Case value via
further Agree.
(iv) H2 agrees with XP and the Case feature of XP gets revalued.
(50) Here I would like to provide further evidence for multiple Case valuation.
(i) Niuean
ergative Case⇒middle Casea. Manako a Sione ke
kai hetau tama
want ABS Sione SUBJNCT eat ERG PL
child‘Sione wants for the children to eat the apples.’eABS

tau apala.
PL appleb. Manako a Sione [he tau tama]ike
kai tie tau apala.
want ABS Sione MID PL
child SUBJNCT eat
ABS PL apple‘Sione wants the children to eat the apples.’(Bejar and Massam 1990: 72)(ii) Greek
nominative Case⇒accusative Caseg. I Maria ekane ton Janiinati klapsi
orgismenos.
the Mary made the John-ACC SUBJNCT
cries-3SG angry-NOM‘Mary made John cry angry.’(Alexiadou et al. 2010: 110; boldface mine)(iii) Korean
dative Case + nominative Caseh. Cheli-hanthey-ka ton-i
isse.
Cheli-DAT-NOM
money-NOM have
‘Cheli has money.’dative Case + accusative Casei. Swunhi-ka Yenghi-hanthey-lul
Swunhi-NOM Yenghi-DAT-ACC

chayk-ul cwuesse.
book-ACC gave10‘Swunhi gave Yenghi the book.’(Levin 2017: 448)(51) The stacked Case values are realized differently from language to language (cf.
Yoon 1996). There are (at least) three possibilities to consider.
(i) Case2+Case1: The last Case value received is realized morphologically.
(ii) Case2+Case1: The first Case value received is realized morphologically.
(iii) Case2+Case1: All the Case values received are realized morphologically.
1.5.2 Multiple Case Valuation via Merge(52) Zushi (2014, 2016) proposes that in non-agreeing languages like Japanese, Casevaluation occurs through (External) Merge.9
a. When a nominal is merged with a lexical head, its case feature is valued as
accusative.
b. When a nominal is merged with a phase head (v or n), its case feature is valued
as nominative or genitive.
c. Otherwise, the case feature of a nominal is valued as dative. (Zushi 2016: 48)(53) The insights of Bruening (2001) and Narita (2007) can be easily and naturally
preserved under the Merge-based Case valuation system as well.
➢ Bruening (2001) and Narita (2007)
Agree only values the unvalued Case feature of a nominal phrase and that theinactivation of it is suspended till the point when it undergoes Transfer.
(54) That is, we can assume that Merge as well as Agree does not render the nominal
phrase inactive and that the inactivation of it is done by Transfer at each phase ina cyclic manner.
➢ a natural consequence of the simplest conception of Merge(55) For example, when the nominal phrase hon ‘book’ is merged with the verb yom‘read’, the nominal phrase is not rendered inactive by Merge. The Case feature ofhon “book” gets valued when it undergoes Transfer.
{hon[uCase], yom-}(56) I thus assume that the nominal phrase hon ‘book’ remains active and can receive
another Case value as long as it is in narrow syntax (by moving to the edge of aphase).
9

See also Saito (2012) for a similar proposal.
11

(57) I also assume that if EM and IM are instantiations of the single operation Merge(cf. Chomsky 2013, 2015a and Epstein, Kitahara, and Seely 2014), then Casevaluation in terms of IM should also be possible in Japanese (contra Zushi 2014,2016).
Assumption:
Case valuation in Japanese occurs through both EM and IM.
(58) If a nominal phrase merged with an appropriate head undergoes IM at Transfer
and becomes a sister of another appropriate head, the two copies receive twodifferent Case values. I will refer to this as multiple Case valuation via Merge.
a.

wo

…

XP[Case1]

b. wo
H2
XP[Case2]

wo
wo
H2

XP[Case1]

H1

Transfer

Internal Merge(59) (i) XP is merged with H1 (a lexical head) and it undergoes IM into the edge of H2(a phase head) at Transfer.10,11 (When the complement of H2 undergoes Transfer,the lower XP receives a Case value.)(ii) The higher XP becomes a sister of H2 (a phase head) when its “complement(s)”undergo(es) Transfer. (Since the higher XP is still in narrow syntax, it remains
active and retains the ability to receive another Case value.)(iii) The higher XP receives another Case value (when it undergoes Transfer).
(60) The idea of multiple Case valuation in Japanese is, in fact, a very old one, dating
Under the proposed system, nothing would prevent the moved XP at the edge of H2 from undergoing further IM
into the edge of the same head, as illustrated below.
(i) [H2P XPi [H2P ti [H1P … ti … ]]].
If H2 corresponds to v, this would yield ga-ga (i.e., nominative-nominative) stacking, which is absent in Japanese.
But the derivation shown in (i) can be excluded if we assume that the relevant movement is “too close” in the senseof Fukui (1993). Fukui (1993) argues that edge-to-edge movement like (i) is prohibited. I would like to thank Toru
Ishii for helpful discussion.
11
If XP undergoes movement into the edge of T, a problematic XP-YP configuration will be created. This problem
would be resolved however, if we follow Fukui (1988) in claiming that Japanese also lacks T in its lexicon and thatthe head of clauses in Japanese is V.
(i) The head of S in Japanese is V, rather than T.
(Fukui 1988: 260)
Translated into the current phase theory, (i) means that the head of S in Japanese is v. If (i) is correct, then it follows
that clauses in Japanese project up to vP. If so, upon completion of a vP phase, the complement of the phase head
undergoes Transfer. Consequently, the label will be determined to v. Alternatively, Takaomi Kato suggests thepossibility that since Japanese lacks C in its lexicon, TP constitutes a phase if we follow Bošković’s (2014) “highestphrase-is-a-phase” approach. If this is correct, upon completion of a TP phase, the complement of the phase head(i.e., vP) undergoes Transfer. Consequently, the label will be determined to T.
1210

back to Kuroda (1965). Under Kuroda’s (1965) system, certain nominal phrases
are introduced into the base structure without Case particles. These “bare”
nominal phrases (i.e., unmarked NPs in Kuroda’s terminology) are ready to getstructural Cases ga (i.e., nominative) and o (i.e., accusative) based on the linear
order of the “bare” nominal phrases.
(61) Kuroda’s cyclic Case marking system allows a nominal phrase to receive morethan one structural Case in the course of a derivation.
a. John-ni
doicugo-ga
deki-ru.
John-DAT German-NOM can-PRES‘John can speak German.’(Kuroda 1965: 190)b. (((John)NP ((doicugo)NP hanas)VP-u)Comp-koto)NP (deki)VP-ru.
c. (((John)NP-ga ((doicugo)NP-o hanas)VP-ru)Comp-koto)NP (deki)VP-ru.
d. (John)NP-ni (((doicugo)NP-o hanas)VP-ru)Comp-koto)NP (deki)VP-ru.
e. (John)NP-ni (doicugo)NP-o (deki)VP-ru.
f. (John)NP-ni (doicugo)NP-o-ga (deki)VP-ru.
g. John-ni doicugo-ga deki-ru.
(Kuroda 1965: 193-194; boldface mine)(62) At the intermediate stage of the derivation (61f), nominative Case (-ga) is assigned
to the nominal phrase doicugo ‘German’ to which accusative Case (-o) has alreadybeen assigned in the first cycle (cf. Kuroda 1978, 1983, 1986).
(63) Kuroda (1965) states that this produces a string of the form NP-o-ga (i.e., NPaccusative-nominative), from which the accusative particle o will have to bedeleted.
(64) Doubling of structural Cases is a natural consequence of the system of cyclic Caseassignment since the structural Cases ga and o are assigned cyclically and o will
be seen as “unmarked” at the next cycle. In relation to this, Kuroda (1983) states
the following.
“I assume, as in my earlier work, that nominative case marking can override (i.e.,
can be superimposed on) any case-marker that originates in an embedded sentence.
The possibility of double case marking, then, is another parametric difference.”(Kuroda 1983: 246; boldface mine)(65) The theory of multiple Case valuation via Merge that I am proposing can thus beseen as a modern revival of Kuroda’s insights which have largely been discounted
in the literature. But it is designed to predict more of what is possible in thegrammar of Japanese.

13Case Realization under Kuroda’s theory
a. ✓Case2+Case1
b. *Case2+Case1
Case Realization under Our Theory
a. ✓Case2+Case1
b. ✓Case2+Case1

14c. *Case2+Case1c. ✓Case2+Case1

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