Case in GB/Minimalism*
Jonathan David Bobaljik and Susi Wurmbrand
University of Connecticut

Case Theory in GB/Minimalism is about the distribution of NPs, not about morphologicalform per se. In this theory, “abstract case” plays a central role in being one of the driving
forces of movement, uniting a variety of transformations (passive, raising, unaccusative,etc.), and in regulating alternations between overt and unpronounced subjects in nonfinite clauses. In the original presentation of Case Theory in Chomsky (1980), abstract
Case is related to the morphological property case via the hypothesis that the formalfeatures that regulate the syntactic distribution of NPs are the same features that are
overtly realized as case morphology in some languages.1 As the theory developed, and inparticular after prominent attention was given to quirky case in Icelandic and ergative
case systems, the connection between Case (a formal feature underlying syntactic
licensing of NPs) and case (the morphological category) became more tenuous, though
the connection between the two is still a live topic of inquiry, with views spanning thespectrum of possibilities.
1. CASE THEORY IN GB
1.1 The Case Filter
Case Theory is first proposed in the defining works of the GB framework (Chomsky
1980, 1981) as a solution to the puzzling distribution of lexical (i.e., phonologicallyovert) NP subjects of infinitival clauses in English, as illustrated in (1). In general, thesubject of an infinitive must not be an overt NP ((1a,e)), but this restriction is lifted when
the infinitival clause is the complement of a particular class of matrix verbs, such as
believe (1b), or when the infinitival clause contains the prepositional complementizer for(1c,d). Where an overt lexical NP subject is prohibited, the subject of the infinitive isassumed to be the silent pronominal element PRO, the interpretation of which isdetermined by Control Theory.
(1)

a.
b.
c.
d.
e.

Leo decided [ (*Lina/himself) to leave ] .
Leo believed [ Lina to be a genius ]Leo decided [ for Lina to leave ]For Leo to win would be great.
*Leo to win would be great.

Prior to the advent of Case Theory, this distribution fell under the purview of the *NP-toVP filter of Chomsky & Lasnik (1977), given in (2).
* We thank Željko Bošković and an anonymous reviewer for their comments on a draft of this chapter.

Space limitations have kept us from addressing all of their comments, and from doing justice to various
topics within Case Theory.
1 We write “Case” for the abstract theoretical entity in GB and Minimalism, and “case” for the traditional

morphosyntactic notion. As discussed below, the two notions were originally held to be directly related, but
the relationship has grown more abstract.

1

(2)

* [α NP to VP], unless α is adjacent to and in the domain of Verb or for ([-N])The major result of Case Theory is the deduction of (2), itself little more than a summaryof the facts in (1), from assumptions that are argued to be independently necessary, alongwith one new assumption, of far broader generality than the construction-specific filter in(2). This new assumption, the key element of Case Theory is the proposal that all lexicalNPs (i.e., NPs other than PRO or NP-trace) require Case, even in Modern English, where
the morphological exponence of case is limited to the pronominal system. This proposal(which Chomsky attributes to Jean-Roger Vergnaud) is formalized as the Case Filter,
given in one version in (3).2(3)*NP if NP has phonetic content and has no Case

(Chomsky 1981, 49)

Given the Case Filter, the distribution in (1) may be largely deduced from independently
motivated rules of Case assignment. A rather rudimentary statement of Case assignmentfor English (and similar nominative-accusative languages) is given in (4):
(4)

a.
b.
c.

subject of tensed clause:
object of verb:
object of preposition:

nominative
accusative
accusative (or oblique)

The (descriptive) content of (4) is a necessary part of any grammatical description ofEnglish and summarizes the observed basic distributional facts for elements that bear
overt case inflection. Absent from (4) is any reference to the subject of a non-finite
clause. Given the Case Filter, the absence of case assignment rules applying to thesubjects of infinitives translates into the exclusion of lexical NPs from this position. In
addition, the “unless” clause of (2) begins to make sense when viewed from theperspective of Case. That is to say, verbs and prepositions have the distinctive
characteristic of being (accusative) case assigners, and thus the disjunctive environment
stipulated in the “unless” clause is none other than the domain of accusative caseassignment.3 What (2) amounts to is that the subject of an infinitive may not be lexical,
unless it is in the domain of a case assigner. This proposition is straightforward for the
NP following for in (1c,d) but requires some additional assumptions for the NP in theinfinitival complement of believe (1b), to which we now turn.
The contrast in (1a-b) shows that there is some difference between the class of verbs
represented by decide and that represented by believe. The Case Filter provides anaccount of this contrast, if what is special about the believe class is that they permit Caseassignment across a non-finite clause boundary.4 That the NP in the complement of
2 Note that the Case Filter does not ban a phonetically empty element with Case. Thus in early GB

implementations, wh-trace is taken to be Case-marked, and a moved wh-phrase satisfies the Case Filter via
its trace. In later implementations, the Case Filter applies to A-chains.
3 This same property (being Case assigners) accounts for why, in English, only V and P may take NP

complements. Adjectives and nouns are not case assigners, and thus are limited to PP and CP complements,
requiring of where a corresponding verb might take an NP complement (cf. refuse the offer vs. refusal of
the offer). For an alternative approach to complementation asymmetries, within the Minimalist Program but
without appeal to Case, see Pesetsky & Torrego 2004.
4 Proposals in the GB framework for allowing Case assignment across the infinitival clause boundary vary

in details, but share the common core that the complement of the believe class verbs is (or becomes, after adeletion operation) smaller than the complement of the decide class (control verbs). Updating the notation,2

believe is indeed receiving Case as if it were the object of believe is supported by various
diagnostics, for example, the loss of accusative in this position when believe ispassivized, and the somewhat murky adjacency requirement between believe and the NP
that is characteristic of objective case assignment in English (see below). The lexical
subject of the non-finite complement of believe avoids the fate of other infinitival
subjects (i.e., limitation to PRO) because in this configuration (which would come to be
known as Exceptional Case Marking or ‘ECM’), it is subject to Case assignment.
In sum, Case Theory constituted a significant advance in deducing the major effects of arather puzzling, essentially descriptive, filter (the *NP-to-VP filter), largely fromindependently motivated elements of the theory (as in (4)) together with a very broad,and not construction-specific assumption, the Case Filter (3).5
1.2 Extensions: Case Theory
The main interest in Case Theory in GB and on into Minimalism lies not in the original
empirical result, but in the consideration of a variety of intricately connectedconsequences. The postulation of the Case Filter had ramifications well beyond the
distribution of infinitival subjects.
For example, Case could now be seen as one of the driving forces of movement for avariety of constructions. Thus, a unified account of promotion to subject in passive (5),raising (6), and unaccusatives (7), became possible: in each construction, the NP in its
original position is not governed by a case assigner, and thus in each configuration, theNP must raise to finite subject position in order to satisfy the Case Filter. The Case Filter
thus becomes one of the answers to the perennial question of why movement occurs, inthe examples at hand, with reference to why movement to subject position occurs in
English.
(5)

a.
b.
c.

Lina was kissed t (by Leo).
Kai was believed [ t to have won the soccer match.]
The birdcage was found [ t empty ].

(6)

a.
b.

Lina seems [ t to like her brother ].
Lina is likely [ t to fall asleep ].

(7)

a.
b.

Jeffrey’s bus arrived t.
The tree fell t.

Note, though, that a Case-based account of movement in these configurations is largely
redundant with another core postulate of GB, namely the Extended Projection Principle(Chomsky 1982,.10), which includes the requirement that every finite clause have asubject (compare the Final-1 Law in Relational Grammar; see Perlmutter & Postal 1983)
the proposal in Chomsky (1981) is that infinitival complements are CPs, but that believe-type verbs induce
a rule of CP-deletion, hence taking IP-complements at the level relevant for the application of the Case
Filter. In later work, it is suggested that believe selects an IP rather than a CP complement as a lexical
property (Chomsky & Lasnik 1995, 112).
5 Case Theory provides a deduction of the major effects of the *NP-to-VP filter, but does not have exactly

the same empirical coverage. Some effects not subsumed under Case Theory, as well as some empiricalproblems for the *NP-to-VP filter, largely having to do with infinitival relatives, are addressedindependently in Chomsky (1980), where a more comprehensive analysis of infinitival relatives is
proposed.

3

The question of whether this redundancy can be eliminated has long stood as a research
problem in GB/Minimalism.6
Another early result of Case Theory, set out by Stowell (1981), regards the “order ofcomplements” problem. As shown in (8), for verbs in English that select for multiple
complements, it is generally held that the NP argument must precede all other (PP, CP)arguments, at least in “neutral” clauses (i.e., clauses that are not derived by, for instance,
Heavy NP Shift or similar operations which are typically associated with a “special”
intonation).
(8)

a.
b.

Maggie donated [NP her allowance] [PP to the charity].
*Maggie donated [PP to the charity] [NP her allowance].

There is no such ordering effect in the corresponding nominalizations, as shown in (9),suggesting that the restriction is syntactic, rather than semantic, in nature.
(9)

a.
b.

?

[Maggie’s donation [PP of her allowance] [PP to charity]] was nice.
[Maggie’s donation [PP to charity] [PP of her allowance]] was nice.

Similarly, multiple PP complements to a verb may be fairly freely reordered with respect
to one another, in contrast to (8), suggesting that the restriction is specifically about NP
complements.
(10)

a.
b.

?

Julia talked [PP to Jillian’s father] [PP about Tommy].
Julia talked [PP about Tommy] [NP to Jillian’s father].

As Stowell argues, the particular requirement that NP complements precede all others (inEnglish) can be seen as a special case of the general requirement of Case Adjacency,
whereby the direct object of an accusative Case assigner (V or P) must be adjacent to its
assigner (abstracting away from parentheticals and the like).7 Deriving the order ofcomplements from Case Theory meant that these ordering restrictions could be
eliminated from the phrase-structure rules, an important step in the move towards a
generalized X’-Theory, now standard in GB/Minimalism.
The above paragraphs illustrate the way in which Case Theory, originally suggested as analternative to some very construction-specific filters regarding infinitives, could be neatly
applied to a wide range of phenomena, allowing for increased generality of the rules at
each step.
6 Fukui & Speas (1986) propose to reduce the EPP to Case Theory, by assuming that nominative caseassignment must be established in overt syntax, by movement (rather than government or Agree). This idea
(sometimes called the Inverse Case Filter) has been advocated within the Minimalist Program, see
Bošković (2002) and especially Epstein & Seely 2006. It is not clear that this involves a genuine reduction,
inasmuch as the empirical scope of the EPP and classic Case Theory are not identical. The core of Case
Theory is held to be universal, while the obligatory NP-movement to subject position seen in English is amatter of parametric variation (cf. Chomsky 1981, 27-28, and for more detailed recent arguments that the
EPP is parameterized within Germanic, see Wurmbrand 2006 and references therein, especially Haider
1993, 2006). An opposing direction for the elimination of the redundancy, represented within
GB/Minimalism by Marantz 1991 and others subsequently, is that the EPP be retained as a languageparticular property, and Case Theory be abandoned. See the discussion in section 2, below.
7 Stowell also considers the strong tendency for finite sentential complements (CPs) to extrapose, for which

he introduces the Case Resistance Principle, and the assumption that CPs may not bear Case.

41.3 Government
Although (4) suffices as a good first pass at a description of Case assignment rules, thearticulation of the details proved to be an important area of inquiry, largely because
grammatical functions (subject, object) have been taken in GB and related frameworks to
be derivative, structurally defined notions (see Chomsky 1965). From this perspective, anadequate characterization of the domain of objective case assignment seemed to requirereference to two notions, namely c-command and adjacency. In formalizing the domainof Case assignment to capture the results discussed above, Chomsky (1980, 25) defines
the notion of government. The original formulation is given here:(11)

α is governed by β if α is c-commanded by β and no major category or major
category boundary appears between α and β.

The proper definition of government, and in particular, the formulation of what it means
for a category to “appear” (or later to “intervene”) between α and β was one of the mostsignificant technical questions of the 1980s (see Aoun & Sportiche 1983, Chomsky 1981,
1986, Lasnik & Saito 1984, 1992 and Rizzi 1990 for a sample of important works). In
Chomsky (1980), the definition was intended to subsume linear adjacency as well as
structural intervention, though in most later work the adjacency condition on government,
and hence on Case assignment, was held to be derivable from other properties of thetheory (see, among others, Johnson 1991). Within the GB framework, the government
relation, motivated originally for Case, was proposed to be a key notion at work in some
way or another in a variety of modules of the theory; a derivative notion, proper
government, playing a central role in subject-object asymmetries in extraction and related
topics for example (see Chomsky 1986, and work cited there, especially Huang 1982).
Stepping back from the details of a rather extensive literature, there is nevertheless asense in which Case assignment remained at the core of the notion of government,
providing the observable instances of the phenomenon from which the operational notion
is to be generalized. If an NP in some configuration is clearly dependent on a particularelement (V or P) for case, then that configuration must constitute a configuration of
government, and that can be used heuristically to set parameters on the bounds of thedefinition.
1.4 Summary: Case Theory in GB
In sum, Case Theory, comprising at its core the Case Filter and a description of Caseassignment, such as (4), stood very close to the core of the GB framework, with tangible
results that moved the theory forward, and new questions that it opened up. Ultimately
the results of Case Theory would be dependent on successful articulation of the theory ofCase assignment. The explorations of locality, couched in terms of government,
constituted one aspect of the careful formalization of (4). Another area of explorationconsidered the implications of cross-linguistic variation in Case assignment rules (seebelow).
Although the notion government and the various attendant notions provided a greater
technical precision, the basic rules of Case assignment in (4) left open a variety ofquestions, which would later serve as the impetus for a body of work at the transition
from GB to Minimalism. Among the topics which received significant attention wereasymmetries between nominative and accusative (or other) cases, including (i) accusative
was assigned by a lexical head (V or P), but nominative was assigned by a functional
head (finite Infl); (ii) accusative was assigned under c-command (head-complement),
where nominative was assigned under m-command (head-specifier), and (iii) accusative5

assignment was subject, in English, to an adjacency condition (as noted above), whilenominative assignment was not (cf. They probably won’t win, where the auxiliary is
assumed to be in Infl). In addition, an unresolved question was why finiteness should
matter for the assignment of nominative case by Infl.
2. HOW ABSTRACT IS ABSTRACT CASE?
Given the explicit nature of the emerging theory, the ramifications of variation in Caseassignment properties (as discussed in detail throughout this volume) would havepredictable consequences for observable phenomena, and to some degree this was
exploited with successful results. For example, Chomsky (1981, 122-123), discussing thework of Burzio (1981), suggests that Italian has a rule of nominative Case assignment to
the post-verbal position, where English lacks such a rule. Under a Case-Theoretic
approach to movement in passive, as sketched above, this difference in Case entails that
Italian lacks obligatory NP-movement to the preverbal subject position in the
counterparts to the English examples in (5).
On the other hand, the foundations of GB Case Theory were taken head on in a landmark
paper on Icelandic Zaenen, Maling and Thráinsson (1985, ZMT). That paper
demonstrated that the original solution to the puzzle in (1) was inadequate, and that thetraditional notion of Case, even allowing for an “abstract” Case (in the sense of caselacking morphological realization), was not the driving force in the distribution of NPs,
neither in the control/ECM alternation nor in the promotion to subject position in passive,
raising and unaccusatives. Space limitations do not permit a thorough review of this work
here, but they key point can be made with reference to a few examples.
Icelandic is a language with overt morphological case distinctions. Transitive
constructions involving a nominative-accusative array work exactly like their English
counterparts—i.e., all the key distributional properties that are held to be the purview ofCase Theory (including ECM, the ban on lexical subjects of infinitives etc.) are robustly
attested in Icelandic as well. In contrast to English, however, Icelandic also has what has
become known as quirky case subjects, that is, subjects which are marked with a caseother than nominative. One such example is given in (12a). The verb hjálpa ‘help’
governs lexical dative case on the object (cf. (12b)) and this case is hence retained in thepassive. Importantly, the dative in (12a) must be seen as the subject of the sentence, a fact
for which ZMT provide ample and convincing evidence, building on earlier work such as
Andrews (1976) and Thráinsson (1979). (On this score, Icelandic contrasts minimallywith German, which has superficially similar examples, but in which the datives are notsubjects). If it is assumed that ‘subjecthood’ is a structural property associated with aparticular syntactic position (e.g., the specifier of IP), one must conclude that the dativeargument moves to this position. This, then, however, is in conflict with a theory whichaims at deriving movement to subject position from the Case Filter. Since the dativearguments receive (lexical) case, they should automatically satisfy the Case Filter in (3),and hence there would be no need for them to move to receive Case.
(12)

a.

Þeim / honumvar
hjálpað.
them / him.DAT was.SG helped‘They/He were/was helped.’ (ZMT, 99, 96)b.

Ég
hjálpaði
honum.
I.NOM helped
him.DAT‘I helped them.’ [ZMT 98]

6

The point can also be made with the control versus ECM distinction, the distributional
puzzle at the historical core of Case Theory. In Icelandic, as in English, the subject of an
infinitive must not be an overt NP, except when the infinitival clause is the complementof an ECM verb, such as telja ‘believe’. However, this distinction cross-cuts casedistinctions. A quirky subject shows exactly the same alternation between PRO andlexical NP as other subjects, but the quirky subject clearly does not depend on believe forits (overt) case—the dative on the NP þeim ‘them’ in (13b) is assigned by the verb ‘help’,
not by tel ‘believe’ (which assigns accusative).
(13)

a

b

Ég
vonast til[að
I.NOM hope forto‘I hoped to be helped.’

PRO

verða
be

hjálpað].
helped(ZMT, 109)

Ég
tel
þeim
hafa
verið hjálpað í prófinu
I.NOM believe them.DAT to.have been helped in exam.the‘I believe them to have been helped on the exam.’(ZMT, 107)

The work of ZMT shows that Case, for the purposes of the Case Filter, cannot be equatedwith the morphological case that is realized on NPs (even allowing for zero-realization,
as on English nouns). ZMT thus argue for the abandonment of Case Theory (a direction
pursued in the GB/MP framework by Marantz 1991 and others), and suggested that therelevant licensing theory be formulated directly in terms of GFs (they thus took theirpaper as support for LFG). Others within the GB framework (Cowper 1988, Freidin &Sprouse 1991) took the ZMT results as instead showing that the Case Filter was correct,
but referred to an even more abstract notion of Case than envisioned in Chomsky(1980,1981), one which may align with the morphologically visible case system in thebasic patterns, but need not do so in all instances. Thus in Icelandic, “abstract
nominative” (the Case of finite subjects) could be realized as morphological nominative(the basic realization), accusative, dative, or genitive, and similarly, “abstract accusative”(the Case of objects, including ECM objects) could also be realized by any of the fourmorphological cases. Largely missing from the debate, so far as we know, are concerted
attempts to show that these two perspectives are distinct in substance, and that thepostulation of “abstract nominative”, for example, is distinct from the postulation of“subject” as a grammatical primitive. Steps towards untangling these views haveappeared only quite recently (see in particular Legate 2005, and for an opposing view
Bobaljik, to appear).
3. CASE THEORY IN THE MINIMALIST PROGRAM
The early 1990s marked a transition from GB to Minimalism as the declared frameworkof choice for many generative syntacticians. A good deal of confusion seems to havearisen around nomenclature. Throughout the Minimalist writings, Chomsky has been atpains to stress that Minimalism is a program, not a theory or theoretical framework. Thatis, in contrast to formal approaches to this point, which have focused on providing
explicit characterizations of grammar (universal and particular) at increasing levels of
abstraction and generalization, Minimalism has been proposed as a set of roughguidelines about the types of questions that may advance linguistic inquiry into thedomain of asking why UG is the way it is. Despite the new focus underlying the
Minimalist Program, the sizeable majority of work cast as Minimalist is characterized bya renewed focus on uniformity and theoretical parsimony, but the goal on the horizon inmost of this work is still (as in GB) an explicit specification of the principles andparameters of UG, in other words, the limits of what it means to be a “possible7

language”. We turn now to a brief outline of where Case Theory fits within Minimalism
in practice, the next phase of the Principles and Parameters framework, and then examine
where Case Theory fits in the (currently programmatic) discussion of what is known as
the Strong Minimalist Thesis.
3.1 Minimalism in practice
For Minimalism in practice, the major questions of Case Theory revolve around thedifferences between nominative and accusative case assignment identified above (section
1.4), and thus, the possibility of developing a uniform theory of nominative andaccusative case assignment.
This has proven to be a productive domain of inquiry, with a variety of proposals for a
unified theory of Case assignment on offer. One perspective (exemplified prominently byChomsky 1991) proposes to assimilate accusative Case assignment to the same type ofstructural configuration as nominative, namely m-command, or in more current terms aspec(ifier)-head relation (see Koopman 2006 for a recent defense, and Wurmbrand 2006
for empirical problems in generalizing spec-head even in the limited domain of
nominative subjects in Germanic). At the other end stands the proposal that all caseassignment, including nominative to the subject, should be characterized by agovernment relation, that is, c-command and locality (see Chomsky 2000, where therelationship is termed Agree). The door to this possibility is opened by assuming that all
subjects in Spec,IP are moved there from lower positions, a proposal originally suggested
by Ken Hale (class lectures) and Koopman & Sportiche (1991). Note that the Agree
perspective, while unifying the mechanisms involved in structural Case assignment, shifts
the burden of the motivation for movement in examples like (5)-(7) away from Case
Theory, to the EPP or an extension thereof.
An additional line of investigation on the theme of a uniform case assigning (or ‘casechecking’, a distinction we set aside here) mechanism concerns the functional versus
lexical difference in the case assigners. Mahajan (1989), Déprez (1989), Chomsky(1991), Johnson (1991) and others postulate VP-external functional projections
responsible for Case on objects, leading to a uniform proposal that Case is assigned byfunctional heads. One striking piece of empirical evidence for this comes from Long
Passive (and Long Unaccusative) in German, Spanish, Japanese and other languages.
Relevant examples are given in (14) and (15)—embedded clauses are used to avid the
additional complications posed by Verb Second. The key point to observe is that it is thevoice distinctions on the embedding verb (in this case versuchen ‘try’) that determine thepossibility of a nominative/accusative case alternation on the object of the embedded
verb. The alternation is passive-like, but it is the voice marking associated with the higher
verb only that determines the case properties in the lower domain. See Wurmbrand(2001) for extended discussion and additional references.
(14)

weil er den/*der Traktor
versucht
since he the.ACC/*NOM tractor
tried‘since he tried to repair the tractor’(15) a.

weil der Traktor
zu reparieren
since the.NOM tractor to repair‘since they tried to repair the tractor’

8

hat
has

[ tOBJ[ tOBJ

versucht wurde
tried
was

zu reparieren]
to repair]b.

weil die Traktoren
zu reparieren
since the tractors (NOM) to repair‘since they tried to repair the tractors’

versucht wurden
tried
were

Though there has been a veritable explosion of proposals, it seems clear that some
reduction of the differences in (11) is a real possibility, within the GB/MP frameworks.
3.2 Programmatic Minimalism
In addition to the technical innovations that characterize Minimalism in practice, a small
minority of Minimalist work poses questions that go beyond specification of theprinciples and parameters of UG, and toy with the key Minimalist question: how close
does language come to “optimal design”, where “optimal design” is to be understood ashaving no properties other than those dictated by the need for the language module tointerface with two other cognitive systems: conceptual-intensional system and the motorarticulatory system. The Strongest Minimalist Thesis (SMT, Chomsky 2001, 1) is theconjecture that language approaches optimality in this very particular sense. Case, inparticular Abstract Case, should leap to the foreground in such a line of inquiry, in theform of the question in (16).
(16)

Why should there be Abstract Case at all?

At first blush, Abstract Case seems problematic for the SMT, in the sense that there is no
obvious interface pressure for its existence. To the extent that there is any temptation to
toy with functionalist explanations, such as the identifying and distinguishing functions ofcase recognized by Mallinson & Blake (1981), Comrie (1989) and others, these seem illsuited to the core examples of Abstract Case at work in languages such as English where
Case is not marked.
One speculation (see, e.g., Chomsky 2004) is that abstract Case features, now generalized
as part of a system of uninterpretable formal features, lie at the heart of the linguisticcoding of what Chomsky refers to as the “duality of semantics” (Chomsky 2004, 7), oneside being thematic relations/argument structure, and the other being information
structure and scopal relations. Under the most recent conception, Case features allow for
the proper working of the Probe-Goal system, a feature-checking mechanism that is in aloose sense the descendent of licensing under government. Another speculation (seePesetsky & Torrego 2001) is that what we call Case is in fact the NP analogue of tense in
the verbal system. As pointed out above, at the time of writing, that aspect of the
Minimalist Program which focuses on the SMT and questions at a similar level is,according to Chomsky, a research program, still in its infancy. We believe it is fair to saythat the jury is still out as to whether this perspective will yield new insights in thisunexplored terrain, in large part due to a paucity of evidence concerning the properties of
the interfaces.
4. TOPICS IN CASE THEORY WITHIN GB/MINIMALISM
In closing, we note briefly three additional topics that have received prominent attention
from the perspective of Case Theory within GB and/or Minimalism. In some sense, eachof these topics constitutes an add-on to the core Case Theory, in that the proposals citedhave had less influence on the direction Case Theory has taken than the topics considered
above.

9

4.1 Null Case
The ECM/control distinction (1a-b) at the historical heart of Case Theory received
renewed attention in the early Minimalist period. The original analysis relied on three
stipulations: (i) a selectional difference for the infinitival complements of ECM (IP) vs.
control (CP) verbs, (ii) the absence of a Case assignment rule to the subject position of
infinitives (see (4)), and (iii) exempting the NP PRO from the Case Filter. One strand of
inquiry asked whether these stipulations might not be derivable, at least in part. The
major investigation in this area centred on Stowell’s (1982) observation (developed in
more detail in Pesetsky 1992) that control infinitives are typically future irrealis
infinitives, whereas ECM infinitives are typically propositional infinitives.8 Building on
this observation, Chomsky & Lasnik (1995), Bošković (1996, 1997), Martin (1996, 2001)
proposed an amendment to (4) whereby the subjects of “tensed” infinitives (those with afuture irrealis interpretation) do assign Case to their subject position, but the Caseassigned is a special “Null Case” that only PRO (but not lexical NPs) may bear. Under
this view, the Case Filter could thus be taken to regulate all NPs including PRO, an(apparent) reduction in the stipulations needed to account for the difference. The Null
Case approach has proven controversial within the MP, though (see Landau 2000, Baltin& Barrett 2002, Hornstein 2003, Cecchetto 2004, Wurmbrand 2005, To appear, for avariety of empirical and theoretical challenges). One of the most serious problems raisedfor the Null Case view is that the presence vs. absence of “infinitival tense”—thepredictor of Null Case—has itself not been shown to be predictable on independent
grounds, leaving Null Case as possibly simply a notational variant of the earlier account.
Another challenge for Case Theoretic treatments of the ECM/Control distinction,(problematic for both the Null Case view and the original Case Theoretic analysis in
section 1) comes from languages in which the subject of (non-ECM) infinitives receives adetectable morphological case (not Null Case). Once again, Icelandic has played an
important role in the discussion since morphological case on PRO is detectable via
elements that show agreement in case with the subject position (see Sigurðsson 1991). A
different aspect of this problem (noted already in Chomsky 1981, 140, n. 25) is posed bylanguages that allow overt, case-marked subjects of non-finite, non ECM clauses, such as
accusative subjects in Latin and Greek.
4.2 Ergativity and Case Typology
Within GB (and to a lesser degree in Minimalism), Case Theory was dependent uponrules of Case assignment, which were held to be a point of cross-linguistic variation (seesection 2). Perhaps the most striking aspect of cross-linguistic variation in(morphological) case lies in the existence of alignments other than nominativeaccusative, including ergative (and split-ergative) systems (Bickel and Nichols, thisvolume). Ergativity received a treatment early in the GB period in Marantz 1981, with avariety of subsequent proposals in both the GB and Minimalism frameworks, (see Butt
2006, chapter 6, for a survey and Johns, Massam & Ndayiragije 2006 for a collection ofrecent views).
Perhaps the most important question of this literature (still unresolved) is whether
ergativity is a syntactic or morphological phenomenon, in other words, whether the
8 As shown in Pesetsky (1992), the picture is, in fact, far more complex. However, we abstract away fromvarious complications here.

10different morphological case patterns are correlated with any syntactic differences. This
was a particularly important question in the early GB period, when (structural) Case was
equated with (morphological) case. In that framework, since the rules of case assignment
in an ergative system are different from those in a nominative-accusative system, thismorphological difference should have repercussions, via Case Theory, for the syntax. For
example, in an ergative system, (by definition) the case assigned to an intransitive subject
is the same as that assigned to the object (not the subject) of a transitive clause. Within
GB and Minimalism, subject and object Cases are distinct in many syntactic ways. One
such difference is that the subject case, but not the object case, was held to be tied to thefiniteness of the clause (but see Sigurðsson 1991). In a Case-Theoretic approach toergativity, this difference might be expected to play out as a restriction whereby onlytransitive subjects are obligatorily suppressed in infinitives, but where intransitive
subjects pattern with objects in being freely expressed, even in infinitives. Bobaljik(1993), developing ideas from Levin & Massam (1984), explores a pattern of agreementin Inuit languages that may be described in these terms. The relevance of ergativity to
Case Theory becomes less obvious, though, with the post-ZMT recognition of a more
abstract relation between Structural Case (the abstract, syntactic licensing) andmorphological case. Like quirky case, this further level of abstraction leaves open thepossibility that ergativity is best described as a morphological phenomenon, lying
squarely outside the domain of Case Theory, and masking a (more) uniform syntax. We
note as well that more extensive investigation of a variety of languages with ergative caseand/or agreement systems suggests that ergativity is not a uniform phenomenon, and that
there is considerable syntactic variation among languages with ergative case systems, andhence the questions just raised must be asked not for ergativity as a phenomenon, but forindividual languages or groups thereof.
4.3 Case, agreement and beyond
A final important topic that has been explored within GB and Minimalism concerns therelationship of Case and case to other features of the grammatical system. The position
taken by Chomsky in the Minimalist writings is that case and agreement are instantiationsof the same fundamental grammatical relationship, representing head versus dependent
marking of that relation (although what the precise relationship is has shifted over thecourse of the Minimalist period).9 Here, as above, Icelandic evidence has played aprominent role, since in Icelandic agreement is indeed intricately connected to(morphological case): only nominative NPs may govern agreement on the finite
predicate, and they do so regardless of grammatical function: nominative objects trigger
agreement, while non-nominative subjects do not (see Sigurðsson 1996; for evidence that
it is case and not grammatical function that determines agreement controller in a varietyof languages, see Falk 1997 and Bobaljik, to appear). The Icelandic evidence issomewhat of a two-edged sword, though, since it is precisely the non-nominative subjects
that have the distribution attributed, in GB, to abstract nominative structural Case, while
the nominative objects were (implicitly, at least) treated as bearing abstract accusative.
9 Inasmuch as the relationship between (structural) Case and (morphological) case is transparent, this view

would be simply incorrect in light of the many well-attested “mismatches” between case and agreement
Such mismatches include the type of ergative split in Warlpiri or Chukchi in which ergative-absolutive casemarking occurs alongside subject-object (nominative-accusative) alignments in agreement (see Dixon
1994), and also more intricate mismatches such as Basque Ergative Displacement (Laka 1993, Hualde &Ortiz de Urbina 2003), and the Chukchi Spurious Antipassive (Spencer 2000, Hale 2002, Bobaljik &Branigan 2006). See Legate (2005) for one attempt to defend the canonical Minimalist view in light of suchapparent counter-evidence.

11

For recent perspectives on nominative objects and review of the current literature, seeHiraiwa (2005) and Nomura (2005).10
The trajectory exemplified by the focus on the abstract features underlying case andagreement is arguably carried a step further in Chomsky’s later Minimalist writings. For
example, Chomsky (2000) signals a shift in emphasis, if not in substance, to a more broad
category of “uninterpretable features”. In many ways, the latest position advocated by
Chomsky has come ever closer to the position forwarded by Marantz 1991, a position
which maintains, from GB’s Case Theory/Case Filter, a component of formal licensing
for NPs, not deducible from semantic or phonological (i.e. “interface” requirements), but
for which case plays little role, beyond the observation that case and agreement areamong the possible morphological signals of this formal licensing. We close with apassage from Chomsky (2000) setting out this view.11
According to this conception, agreement (hence movement) is driven by uninterpretable featuresof the probe, which must be deleted for legibility… With this shift in perspective, structural Caseis demoted in significance. The Case Filter still functions indirectly in the manner of Vergnaud’s
original proposal, to determine the distribution of noun phrases. But what matters primarily are theprobes, including φ-features [person, number, gender –B&W] of T, v. That reverses much of therecent history of inquiry into these topics and also brings out more clearly the question of why
Case exists at all. The question arises still more sharply if matching is just identity, so that Casecan never be attracted; operations are not induced by Case-checking requirements. (Chomsky
2000: 127).

REFERENCES
Aoun, Joseph, and Dominique Sportiche (1983). 'On the formal theory of government'
The Linguistic Review 2: 211-236.
Baltin, Mark and Leslie Barrett (2002). 'The Null Content of Null Case' Unpublishedmanuscript, New York University.
Bobaljik, Jonathan David (1993). 'On ergativity and ergative unergatives' in Colin
Phillips (ed.), Papers on Case and Agreement II, MIT Working Papers in
Linguistics 19, 45-88.
Bobaljik, Jonathan David (to appear). 'Where's phi? Agreement as a post-syntactic
operation' in David Adger, Daniel Harbour, and Susana Béjar (eds.), Phi-Theory:
Phi features across interfaces and modules. Oxford: Oxford University Press.
Bobaljik, Jonathan David and Phil Branigan. (2006). 'Eccentric Agreement and Multiple
Case Checking', in Alana Johns, Diane Massam & Juvenal Ndayiragije (eds.),
Ergativity: Emerging Issues, Dordrecht: Springer, 47-77.
Bošković, Željko (1996). 'Selection and the categorial status of Infinitival Complements.'
Natural Language and Linguistic Theory 14:269-304.
10 As in many domains, subtle differences in the use of key terms (abstract, inherent, lexical, structural, andquirky) among authors have contributed to the complexity of the debate.
11 Although we focus on Chomsky’s writings as the canonical instantiation of Minimalism, it is well worth

noting, as Chomsky does, that there a variety of current, mutually incompatible, theoretical proposals in the
Minimalist literature that share certain core assumptions. With regards to Case Theory, Legate (2005) andBošković (to appear) maintain a view of Case more in line with later GB proposals than suggested in thepassage from Chomsky.

12

Bošković, Željko (1997). The syntax of nonfinite complementation: An economy
approach. Cambridge, Mass: MIT Press.
Bošković, Željko (2002). 'A-Movement and the EPP.' Syntax 5:167-218.
Bošković, Željko (to appear). 'On the locality and motivation of Move and Agree: aneven more minimal theory.' Linguistic Inquiry
Burzio, Luigi (1981). Intransitive Verbs and Auxiliaries. Ph.D. Dissertation, MIT,
Cambridge, Mass.
Butt, Miriam (2006). Theories of Case. Cambridge: Cambridge University Press.
Cecchetto, Carlo (2004). 'A challenge to Null Case theory.' Linguistic Inquiry 35.1:141149.
Chomsky, Noam (1965). Aspects of the Theory of Syntax. Cambridge, Mass: MIT Press.
Chomsky, Noam (1980). 'On Binding.' Linguistic Inquiry 11:1-46.
Chomsky, Noam (1981). Lectures on Government and Binding. Dordrecht: Foris.
Chomsky, Noam (1982). Some Concepts and Consequences of the Theory of Government
and Binding. Cambridge, Mass: MIT Press.
Chomsky, Noam (1986). Barriers. Cambridge, Mass: MIT Press.
Chomsky, Noam (1991). 'Some Notes on the Economy of Derivation and
Representation.' In Robert Freidin, (ed.) Principles and Parameters in
Comparative Grammar. Cambridge, Mass: MIT Press, 417-454.
Chomsky, Noam (2000). 'Minimalist Inquiries: The Framework.' In Roger Martin, David
Michaels, and Juan Uriagereka, (eds.) Step by step. Essays on Minimalist syntax
in honor of Howard Lasnik. Cambridge, MA: MIT Press, 89-155.
Chomsky, Noam (2001). 'Derivation by phase.' In Michael Kenstowicz (ed.) Ken Hale: Alife in language, Cambridge, Mass: MIT Press, 1-52.
Chomsky, Noam (2004). On phases. Ms., MIT,
Chomsky, Noam, and Howard Lasnik (1977). 'Filters and Control.' Linguistic Inquiry 8:425-504.
Chomsky, Noam, and Howard Lasnik (1995). 'The Theory of Principles and Parameters.'
In Noam Chomsky (ed.) The minimalist program. Cambridge, MA: MIT Press,
13-127
Comrie, Bernard (1989). Language Universals and Linguistic Typology. Chicago:
University of Chicago Press.
Cowper, Elizabeth. (1988). 'What is a subject? Non-nominative subjects in Icelandic,' in J
Blevins & J Carter (eds.), Proceedings of NELS, GLSA, Amherst.
Dixon, R. M. W. (1994). Ergativity. Cambridge, UK: Cambridge University Press.
Déprez, Viviane (1989). On the Typology of Syntactic Projections and the Nature of
Chains: Move-a to the Specifier of Functional Projections. Ph.D. Dissertation,
MIT, Cambridge, Mass.
Epstein, Samuel David, and T. Daniel Seely. (2006). Derivations in Minimalism.
Cambridge: Cambridge University Press.
Falk, Yehuda N. (1997). Case typology and Case Theory. Ms., Hebrew University,
Jerusalem.
Freidin, Robert, and Rex A. Sprouse (1991). 'Lexical case phenomena.' In Robert Freidin,(ed.) Principles and Parameters in Comparative Grammar. Cambridge, Mass:
MIT Press, 392-416.
Fukui, Naoki & Margaret Speas. (1986). 'Specifiers and Projection', in Naoki Fukui, Tova
R Rapoport and Elizabeth Sagey (eds.), Papers in Theoretical Linguistics, MIT
Working Papers in Linguistics, 8, 128-172.
Haider, Hubert (1993). Deutsche Syntax Generativ. Tübingen: Narr.
Haider, Hubert (2006). 'Mittelfeld phenomena.' In Martin Everaert and Henk van
Riemsdijk (eds) The Blackwell Companion to Syntax. Oxford: Blackwell.
Hale, Ken. (2002). 'Eccentric Agreement.' in Beatriz Fernández & Pablo Albizu (eds.),
Kasu eta Komunztaduraren gainean [On Case and Agreement], Euskal Herriko
Unibetsitatea, Vitoria-Gasteiz, pp. 15-48.
13

Hiraiwa, Ken. (2005). Dimensions of Symmetry in Syntax: Agreement and Clausal
Architecture, Ph.D. Dissertation, MIT,
Hornstein, Norbert. (2003). 'On control,' in Randall Hendrick (ed.). Minimalist syntax,
Oxford: Blackwell, 6-81.
Hualde, José Ignacio and Jon Ortiz de Urbina (eds.). (2003). A Grammar of Basque,
Mouton, Berlin.
Huang, C.-T. James (1982). Logical Relations in Chinese and the Theory of Grammar.
Ph.D. Dissertation, MIT, Cambridge, Mass.
Johns, Alana, Diane Massam, and Juvenal Ndayiragije (2006). Ergativity: Emerging
Issues. Dordrecht: Springer.
Johnson, Kyle (1991). ‘Object Positions.’ Natural Language and Linguistic Theory
9:577-636.
Koopman, Hilda (2006). ‘Agreement configurations: In defense of "Spec head".’ In
Cedric Boeckx (ed.) Agreement Systems. Amsterdam: Benjamins, 159-199.
Koopman, Hilda, and Dominique Sportiche (1991). ‘The position of subjects.’ Lingua
85:211-258.
Laka, Itziar. (1993). ‘The structure of inflection: a case study in X˚ syntax’ In José
Ignacio Hualde and Jon Ortiz de Urbina (eds.), Generative Studies in Basque
Linguistics, Amsterdam: John Benjamins, 21-70.
Landau, Idan (2000). Elements of control: Structure and meaning in infinitival
constructions. Dordrecht: Kluwer.
Lasnik, Howard, and Mamoru Saito (1984). 'On the nature of proper government.'
Linguistic Inquiry 15:235-289.
Lasnik, Howard, and Mamoru Saito (1992). Move-α. Cambridge, Mass: MIT Press.
Legate, Julie Anne (2005). Morphological and abstract case. Ms., University of
Delaware,Levin, Juliette, and Diane Massam (1984). 'Surface Ergativity: Case/Theta-relations
reexamined.' In S. Berman (ed.) Proceedings of NELS 15.
Mahajan, Anoop. (1989). 'Agreement and agreement phrases' In Functional heads andclause structure: MIT Working Papers in Linguistics 10, 217-252.
Mallinson, Graham and Barry J. Blake. (1981). Language Typology: Cross-linguistic
studies in syntax, North Holland, Amsterdam.
Marantz, Alec. (1981). On the nature of grammatical relations, Ph.D. Dissertation, MIT,
Cambridge, Mass.
Marantz, Alec. (1991). 'Case and Licensing', in German Westphal, Benjamin Ao & HeeRahk Chae (eds.), Proceedings of ESCOL ‘91, Cornell Linguistics Club, 234-253.
Martin, Roger Andrew (1996). A minimalist theory of PRO and control. Ph.D.
Dissertation, University of Connecticut, Storrs.
Martin, Roger Andrew (2001). 'Null case and the distribution of PRO.' Linguistic Inquiry
32.1:141-166.
Nomura, Masashi (2005). Nominative case and AGREE(ment). Ph.D. Dissertation,
University of Connecticut, Storrs.
Perlmutter, David M. and Paul M. Postal. (1983). 'Some proposed laws of basic clausestructure', in David M. Perlmutter (ed.). Studies in Relational Grammar 1,
University of Chicago Press, Chicago, 81-128.
Pesetsky, David. (1992). Zero Syntax II: An essay on infinitives. Unpublishedmanuscript, MIT, Cambridge, Mass.
Pesetsky, David and Esther Torrego. (2001). 'T-to-C Movement: Causes andConsequences', in Michael Kenstowicz (ed.). Ken Hale: a Life in Language,
Cambridge, MA: MIT Press, 355-426.
Pesetsky, David, and Esther Torrego (2004). 'Tense, case, and the nature of syntactic
categories.' In Jacqueline Guéron and Jacqueline Lecarme (eds.) The Syntax ofTime, Cambridge, MA: MIT Press, 495-537.
Rizzi, Luigi (1990). Relativized Minimality. Cambridge, Mass: MIT Press.
14

Sigurðsson, Halldór Ármann (1991). 'Icelandic Case-marked PRO and the Licensing of
Lexical Arguments.' Natural Language and Linguistic Theory 9:327-364.
Sigurðsson, Halldór Ármann. (1996). 'Icelandic Finite Verb Agreement', Working Papers
in Scandinavian Syntax, 57, pp. 1-46.
Spencer, Andrew. (2000). 'Agreement morphology in Chukotkan', in Wolfgang U.
Dressler, Oskar E. Pfeiffer and Markus A. Pochtrager (eds.), Morphologicalanalysis in comparison, Amsterdam: Benjamins, 191-222.
Stowell, Tim. (1981). The Origins of Phrase Structure, Ph.D. Dissertation, MIT,
Cambridge, Mass.
Stowell, Tim. (1982). 'The tense of infinitives', Linguistic Inquiry 13, 561-570.
Wurmbrand, Susi. (2001). Infinitives: Restructuring and clause structure, Mouton de
Gruyter, Berlin/New York.
Wurmbrand, Susi. (2005). 'Tense in infinitives', Plenary talk at the workshop on New
Horizons in the Grammar of Raising and Control, LSA Summer Institute,Cambridge, Mass.
Wurmbrand, Susi. (2006). 'Licensing Case', Journal of Germanic Linguistics 18.3, 175234.
Wurmbrand, Susi. (To appear). Infinitives are tenseless, in Proceedings of the 30th
Annual Penn Linguistics Colloquium: Penn Working Papers in Linguistics 13.1.
Zaenen, Annie, Joan Maling & Höskuldur Thráinsson. (1985). 'Case and grammatical
functions: The Icelandic passive', Natural Language and Linguistic Theory 3,
441-483.

15