8 Case theory

This chapter is devoted to a discussion of case, a morphosyntactic property of noun phrases. We begin by illustrating the basic purpose of case, which is to identify a noun phrase's grammatical relation in the sentence (for instance, whether a noun phrase is the subject or object). We also show that particular lexical items can impose morphological case requirements on noun phrases, a phenomenon known as case government. We then turn to how case is expressed across languages, focusing on older and more modern stages of Indo-European, the language family to which English belongs. Universal Grammar allows case, just like tense, to be expressed either synthetically (as suffixes on nouns) or analytically (by means of prepositions or other syntactic heads that take an entire noun phrase as their argument). As we will see, English allows both ways of expressing case (just as it allows both ways of expressing tense in watch-ed and will watch). It is possible to describe both expressions of case in a unitary way by treating case as a feature on a noun phrase that is checked by a head. As we will show, case checking is subject to structural as well as nonstructural licensing conditions.

A first look at case

The basic purpose of case

In order to understand the purpose of case in human language, it is useful to consider languages in which constituent order is not as fixed as it is in English. In German, for instance, unlike English, the subject of an ordinary declarative clause needn't precede the verb, as shown in (1) and (2) (we discuss the structure of German sentences in a later chapter; for now, only the variable constituent order is of interest). In the examples, boldface indicates the subject, and italics indicates the object.

(1) a. German  
Der Mann sieht den Hund.
the  man  sees  the dog
'The man sees the dog.'
Den Hund sieht der Mann.
the  dog  sees  the man
same as (1a)
(2) a.
Der Hund sieht den Mann.
the  dog  sees  the man
'The dog sees the man.'
Den Mann sieht der Hund.
the  man  sees  the dog
same as (2a)

Since German speakers can't reliably identify subjects and objects in terms of their order with respect to the verb, how is it possible for them to keep track of which constituent expresses which grammatical relation? The answer is that grammatical relations are encoded in German in terms of morphological case marking. In particular, the subjects of finite clauses in German appear in a form called the nominative case, whereas direct objects appear in the accusative. (3) gives a morphological analysis of the noun phrases in (1) and (2).

(3) a.  
d-  er  Mann, d-  er  Hund
the nom man   the nom dog
d-  en  Mann, d-  en  Hund
the acc man   the acc dog

As is evident from (3), the distinction between nominative and accusative case is marked in German on the head of the noun phrase, the determiner.

Case distinctions are usually expressed only on the determiner in German, but there are certain exceptional nouns that can be case-marked, as illustrated in (4). '0' indicates a zero nominative suffix; -(en) is the optional accusative suffix.

(4) a. Nominative  
d-  er  Bär- 0,   d-  er  Student-0
the nom bear nom, the nom student nom
b. Accusative  
d-  en  Bär-(en), d-  en  Student-(en)
the acc bear acc  the acc student acc

In (4), case is marked on the noun phrases redundantly, once on the determiner, and once on the noun. In German, this is a historical relic from an earlier stage of the language where such redundant case marking was more extensive. In certain languages, however, redundant case marking on the determiner and the noun is the norm. This is illustrated for modern Greek in (5). In Greek, any of the six possible permutations of subject, verb, and object (SVO, SOV, OSV, OVS, VOS, VSO) in either (5a) or (5b) is a grammatical declarative clause, although not every permutation is felicitous in every discourse context.

(5) a. Modern Greek
O       andr-as  vlepi to      skil-o.
the.nom man  nom sees  the.acc dog acc
'The man sees the dog.'
O       skil-os   vlepi ton     andr-a.
the.nom dog   nom sees  the.acc man acc
'The dog sees the man.'

Finally, in languages without articles, case can be expressed solely on the noun. This is illustrated for Latin in (6); as in modern Greek, all six permutations of subject, verb, and object in (6a) and (6b) were grammatical.

(6) a. Latin
Av-       us  can-em videt.
grandfather nom dog acc sees
'The grandfather sees the dog.'
Can-is  av-         um videt.
dog  nom grandfather acc sees
'The dog sees the grandfather.'

As the examples in this section show, noun phrases can be case-marked either on the determiner, on the noun, or redundantly on both. But regardless of the exact form that case marking takes, it has the same basic purpose: it visibly expresses a noun phrase's function in a sentence.

Case government

In many languages, the particular morphological case that a noun phrase appears in depends not only on its function in the sentence, but also on particular lexical items that it stands in relation to. For instance, in German, the object in a sentence appears in the dative or the accusative,1 depending on the verb, as illustrated in (7) and (8).

(7) a. Dative ok
{ d-  em  Hund, d-  er  Frau } { helfen, nachlaufen }
  the dat dog   the dat woman    help    after.run
'to { help, run after } the { dog, woman }'
b. Accusative *
{ d-  en  Hund, d-  ie  Frau } { helfen, nachlaufen }
  the acc dog   the acc woman    help    after.run
(8) a. Accusative ok
{ d-  en  Hund, d-  ie  Frau } { unterstützen, verfolgen }
  the acc dog   the acc woman    support       pursue
'to { support, pursue } the { dog, woman }'
b. Dative *
{ d-  em  Hund, d-  er  Frau } { unterstützen, verfolgen }
  the dat dog   the dat woman    support       pursue

In traditional grammar, the verb is said to govern the case of the object (for instance, helfen 'help' governs the dative, unterstützen 'support' governs the accusative, and so on). An attractive hypothesis is that the morphological case that a verb governs correlates with the verb's meaning, the idea being that variation in case government as illustrated in (7) and (8) correlates with (possibly subtle) differences in the semantics of helfen 'help' and nachlaufen 'run after' on the one hand and unterstützen 'support' and verfolgen 'pursue' on the other. At present, however, such a hypothesis remains to be fleshed out in detail.

Case government in Latin is illustrated in (9). As in German, each particular verb governs the case of its object, but in Latin, the choice of case ranges over dative, accusative, and ablative.

(9) a. Dative  
{ femin-ae, *femin-am, *femin-a  } { subvenire, succurrere }
  woman dat        acc        abl    help       help
'to help the woman'
b. Accusative  
{ femin-am, *femin-ae, *femin-a  } adiuvare
  woman acc        dat        abl  support
'to support the woman'
c. Ablative  
{ femin-a, *femin-ae, *femin-am } frui
  woman abl       dat        acc  enjoy
'to enjoy the company of the woman'

In both German and Latin, prepositions resemble verbs in governing the case of their complement. In German, prepositions govern the accusative, the dative, or (rarely) the genitive; in Latin, they govern the ablative or the accusative.

(10) a. German  
durch   d-  ie  Tür,  bei d-  er  Kirche,  während d-  es  Krieges
through the acc door  by  the dat church   during  the gen war
'through the door, by/near the church, during the war'
b. Latin  
de    sapienti-a,  ad rip-  am
about wisdom   abl to shore acc  
'about wisdom, to the shore'

Finally, in both German and Latin, certain prepositions can govern more than one case. In such cases, the accusative marks direction, and the other case (dative in German, ablative in Latin) marks location.

(11) a. German  
in { d-  ie, *d-  er } Bibliothek schicken; in { d-  er, *d-  ie } Bibliothek arbeiten
in   the acc  the dat  library    send      in   the dat  the acc  library    work
'to send into the library, to work in the library'
in { bibliothec-am, *bibliothec-a } mittere; in { bibliothec-a, *bibliothec-am } laborare
in   library    acc             abl send     in   library    abl            acc  work
'to send into the library, to work in the library'

Synthetic versus analytic case marking

In the languages that we have been discussing so far, case is expressed synthetically, by means of morphologically complex words. But Universal Grammar also allows noun phrases to be marked for case analytically. The case marker is then not an affix, but a relatively independent syntactic head. We illustrate these two options of expressing case in connection with a brief overview of case in the Indo-European language family, to which English belongs.

Proto-Indo-European (PIE), the reconstructed ancestor of the Indo-European language family (which includes English) which was spoken thousands of years ago, had eight cases, which were expressed synthetically. The nominative marked the subject of finite clauses, the accusative and dative (and perhaps other cases) marked objects (depending on the verb, as just discussed), and the genitive indicated possession. The PIE ablative indicated the source of movement (as in I drove from Chicago), the locative was used for locations (as in I used to live in Chicago), and the instrumental marked instruments or means (as in He cut it with his pocketknife). Finally, the vocative was used to address persons (as in Hey, Tom, come on over here).

The original PIE case system is essentially preserved in Sanskrit, although the distinction between the ablative and the genitive is somewhat obscured in Sanskrit because ablative and genitive forms were often homophonous. Such homophony among two or more case forms is called case syncretism. Among living languages, the PIE system is best preserved in the Baltic languages (Latvian and Lithuanian) and such Slavic languages as Ukrainian and Czech. In these languages, the genitive and the ablative have merged completely, leaving seven cases. In other words, in the history of these languages, case syncretism affected all forms of the genitive and the ablative, not just some of them, and so children learning the language no longer had any evidence anywhere in the language for distinguishing between the two cases. Several other Slavic languages, including Russian, have in addition almost completely lost the vocative, leaving only six cases. In Latin, the PIE ablative, instrumental, and locative merged into a single case, called the ablative, which serves all three functions, leaving six cases. In Ancient Greek, the ablative, instrumental, and locative were lost, leaving five cases. Finally, Germanic languages like German and Old English have retained only the nominative, genitive, dative, accusative, leaving four cases. The developments just sketched for Indo-European are summarized in (12). "R" indicates that a particular case has been retained, whereas "---" indicates that it has been lost. When a merger of two or more cases has taken place, the table gives the name under which the resultant merged case is known.

PIE, Sanskrit Baltic,
some Slavic
Other Slavic Latin Ancient Greek German,
Old English
Nominative R R R R R R
Dative R R R R R R
Accusative R R R R R R
Genitive R genitive genitive R R R
Ablative R ablative --- ---
Locative R R R --- ---
Instrumental R R R --- ---
Vocative R R --- R R ---

(13) shows the complete case paradigms for the Latin nouns avus 'grandfather' and femina 'woman'. These two nouns are each representative of two word classes, or declensions. Latin had five such declensions, each of which was characterized by unique endings for combinations of case and number. For instance, in the declensions to which avus and femina belong, dative singular is expressed by -o and -ae, respectively, whereas in the remaining three declensions, the same combination is expressed by -i. The three declensions in question are in turn distinguished by separate endings for, say, the nominative singular.

(13)     Latin o- declension a- declension
  'grandfather' 'woman'
Sg Pl Sg Pl

Nominative av-us av-i femin-a femin-ae
Genitive av-i av-orum femin-ae femin-arum
Dative av-o av-is femin-ae femin-is
Accusative av-um av-os femin-am femin-as
Vocative av-e av-i femin-a femin-ae
Ablative av-o av-is femin-a femin-is

As (13) shows, Latin exhibited some case syncretism. For instance, the dative and ablative singular are homophonous for avus 'grandfather', the genitive and the dative singular are homophonous for femina 'woman', and the dative and the ablative plural are homophonous for both nouns.

In the descendants of Latin, the Romance languages, case is still expressed synthetically on pronouns. For instance, the distinction between dative and accusative pronouns is illustrated for French in (14). (Note that unstressed pronouns in French are clitics; unlike full noun phrases, they precede the verb they are construed with.)

(14) a.  
Je veux lui        parler.
I  want 3.ps.sg.dat talk
'I want to talk to { him, her. }'
Je veux { le,               la }            voir.
I  want   3.ps.sg.acc.masc. 3.ps.sg.acc.fem see
'I want to see { him, her. }'

With full noun phrases, however, the same distinction is expressed analytically by the presence or absence of the case marker à.

(15) a.  
Je veux parler à votre { frère,  soeur. }
I  want talk     your     brother sister
'I want to talk to your { brother, sister. } '
Je veux voir votre { frère,  soeur. }
I  want see  your     brother sister
'I want to see your { brother, sister. }'

This case marker is etymologically related to the spatial preposition à 'to', but is distinct from it. This is demonstrated by the fact that the pro-form for phrases in which à is a spatial preposition is not lui, as in (14a), but y, just as it is for other spatial prepositions like dans 'in' or sur 'on'.

(16) a.  
Nous avons envoyé le  vin  à  Toulouse; mon ami    habite à  Paris.
we   have  sent   the wine to Toulouse  my  friend lives  in Paris
'We sent the wine to Toulouse; my friend lives in Paris.'
Nous y     avons envoyé le  vin; mon ami    y     habite.
we   there have  sent   the wine my  friend there lives
'We sent the wine there; my friend lives there.'
(17) a.
Le  cadeau  se   trouve dans mon sac; nous avons mis le   cadeau  sur la  table.
the present refl finds  in   my  bag  we   have  put  the present on  the table
'The present is (literally, finds itself) in the bag; we put the present on the table.'
Le cadeau   s'   y    trouve; nous y     avons mis le  cadeau.
the present refl there finds  we   there have  put the present
'The present is there; we put the present there.'

As mentioned earlier, Old English had four cases, which are illustrated in (18) for three declensions. As is evident, case syncretism is more extensive in Old English than in Latin.

Note that Latin is the ancestor of French, but not of Old English; click here for one recent hypothesis for how Latin and Old English are related.

(18)     Old English Masculine Feminine Neuter
    'fox' 'learning' 'animal'
Sg Pl Sg Pl Sg Pl

Nominative fox fox-as lar lar-a deor deor2
Genitive fox-es fox-a lar-e lar-a deor-es deor-a
Dative fox-e fox-um lar-e lar-um deor-e deor-um
Accusative fox fox-as lar-e lar-a deor deor

In the course of Middle English (1150-1500), the old genitive case suffix was lost, and its function was taken over by a syntactic head---the possessive determiner 's (in the plural, the possessive is spelled out as a silent determiner that is orthographically represented as an apostrophe). The old synthetic genitive case is illustrated in (19). As in the previous chapter, +t stands for the Middle English character thorn, which represented the voiceless 'th' sound in thin and thorn.

+te king-es  suster of France (CMPETERB,59.593)
the king gen sister of France
'the king of France's sister'

Although the change itself is not yet fully understood, it is clear that the modern possessive marker is no longer a synthetic case suffix on a noun (king), but rather analytically case-marks an entire DP (the king of France). This is clear from the fact that it follows postnominal adjuncts like the prepositional phrase of France in the translation of (19). The difference between the old synthetic genitive suffix and the analytical possessive determiner that replaced it emerges even more sharply from examples like (20), where the possessive determiner obligatorily follows an element that is not even a noun. For clarity, the noun phrase that is case-marked by the possessive determiner is underlined in (20a); the entire sequence in (20a) from the to cat is of course also a noun phrase.

(20) a.   the guy (that) I used to go out with 's cat
b. * the guy's (that) I used to go out with cat

We ordinarily think of the possessive form of singular noun phrases as containing 's. Under the analysis just given, however, the nominative, possessive, and objective case of a full noun phrase are all homophonous in Modern English, and the determiner 's in the king's is a case marker on a par with the preposition of in of the king.

Although the possessive is marked analytically on full noun phrases, it is spelled out synthetically on pronouns. Much as the combination of a verb like sing and a silent past tense morpheme is spelled out as sang, a pronoun like we (or more precisely, the feature combination first person plural) and a silent possessive morpheme is spelled out as our.

Beginning in late Old English (ca. 1000 C.E.), the distinction between the dative and the accusative weakened, and the distinction was lost completely in the course of Middle English (1150-1500). We refer to the case that resulted from the merger as the objective. The distinction between nominative and objective case continues to be expressed synthetically in modern English on most ordinary pronouns, as illustrated in (21).

(21)     Nominative Objective

1 sg        I        me
2 sg, pl          you        you
3 sg m, f, n        he, she, it        him, her, it
1 pl        we        us
3 pl        they          them  

With the two pronouns you and it, however, the nominative and the objective are homophonous, just as in the case of full noun phrases.

Case features

In the remainder of this chapter, we introduce some concepts and syntactic conditions that enable us to derive the distribution of the various case forms of noun phrases in English and other languages. This section introduces the notion of case feature.

Consider the contrast between (22) and (23).

(22) a. ok They will help her.
b. ok She will help them.
(23) a. * Them will help she.
b. * Her will help they.

Why are the sentences in (23) ungrammatical? The answer is that noun phrases in English are subject to the requirements in (24).

(24) a. Subjects of finite clauses appear in the nominative.
b. Objects appear in the objective.

As is evident, both of the subjects in (23) are objective forms, and both of the objects are nominative forms. Each of the sentences in (23) therefore contradicts the requirements in (24) in two ways.

Now compare the examples in (22) and (23) with those in (25).

(25) a. You will help her.
b. She will help you.

As we saw in (21), they and she exhibit distinct forms for the nominative and objective, whereas you doesn't. But because case syncretism between the nominative and the objective is not complete in English (in other words, because most of the pronouns have distinct forms for the two cases), we will treat you as a nominative form in (25a), equivalent to they and she, but as an objective form in (25b), equivalent to them and her. For the same reason, we treat the noun phrase my big brother as a nominative form in (26a) and as an objective form in (26b).

(26) a. My big brother will help her.
b. She will help my big brother.

In order to disambiguate instances of case syncretism like you and my big brother, it is useful to assume that each noun phrase in a language bears a case feature. Each case feature can assume a value from among all the various case forms in that language (regardless of whether the case forms are expressed synthetically or analytically). In English, for instance, there is a choice among three values (nominative, possessive, objective), whereas in Russian, there is a choice among six (nominative, genitive, dative, accusative, locative, instrumental). We can represent the values of case features as in (27) and (28).

(27) a.   [DP-nom They ] will help [DP-obj her. ]
b.   [DP-nom You ] will help [DP-obj her. ]
c.   [DP-nom My big brother ] will help [DP-obj her. ]
(28) a.   [DP-nom She ] will help [DP-obj them. ]
b.   [DP-nom She ] will help [DP-obj you. ]
c.   [DP-nom She ] will help [DP-obj my big brother. ]

Case checking

Earlier, we said that the purpose of case is to encode a noun phrase's function in a sentence. More specifically, we can think of a noun phrase's function as being tied to some particular syntactic head. A widespread way of putting this is to say that the case feature on a noun phrase needs to be checked against a corresponding case feature on a head. If the case features on the two participants in a checking relationship don't match up (say, one is nominative and the other is accusative) or if they don't stand in a one-to-one relationship (say, the case feature on a head ends up checking case features on more than one noun phrase), then the sentence is ungrammatical. On the other hand, if every case feature in a sentence stands in a one-to-one relationship with a corresponding partner, then all is well with the sentence as far as case theory is concerned. A question that arises is whether case checking is subject to structural constraints. If so, we are of course interested in providing as general a formulation of those constraints as possible.

Case licensing

There is reason to believe that there is more than one type of case checking. We can distinguish between what we will call case licensing, which holds between a noun phrase and a head external to the noun phrase (say, a verb or preposition), and case agreement, which holds within a noun phrase (say, between a determiner and a noun). In the current version of this book, we will discuss only case licensing. In this section, we motivate various conditions (primarily structural, but also nonstructural) on the relationship between the two participants in a case-licensing relation. In the first half of the section, we present three structural configurations in which case licensing is possible: the specifier-head configuration, the head-specifier configuration, and the head-complement configuration. Beginning in the 1990's, attempts have been made to simplify the theory of case licensing by identifying a single case-licensing configuration. For instance, it has been proposed that complements of verbs are not directly licensed in the head-complement configuration, but that the complement moves to the specifier of a silent head, and that case is uniformly licensed in the specifier-head configuration. Our own discussion will remain somewhat agnostic on this point, but we will show that the head and the noun phrase in the three configurations mentioned above lie on a particular type of path. In the second half of the section, we discuss three further nonstructural conditions on case licensing: biuniqueness, exocentricity, and matching.

Specifier-head licensing.

In what follows, it's important to distinguish carefully between finite verbs on the one hand and finite clauses on the other (see Verbs for more discussion). In English, finite clauses are clauses that can stand on their own. Finite verbs are ones that aren't infinitives or participles. All four of the clauses in (i) and (ii) are finite because they can stand alone. But the verbs (in italics) are nonfinite in (i), and finite only in (ii).

(i) a. Modal + infinitive   I will do that; he will do that.
b. Present tense auxiliary verb + present participle   I am doing that; he is doing that.
c. Present tense auxiliary verb + past participle   I have done that; he has done that.
(ii)   Silent tense + finite verb   I [pres] do that; he [pres] does that.

English also has nonfinite clauses, which cannot stand alone. These may contain the nonfinite Infl element to. The verb of a nonfinite clause is always nonfinite; hence the grammaticality contrast in (iii).

(iii) a. Nonfinite Infl + infinitive   to do that
b. Nonfinite tense + finite verb * to does that

We begin by considering how case is licensed on the subjects of sentences. Since subjects of sentences start out as specifiers of verbs, one's first impulse might be to propose that nominative case is checked by V. Although we will reject this approach, let us pursue it for the moment in order to show why it is unsatisfactory. The proposal is that what checks the nominative case of He (or more precisely, its trace in Spec(VP)) is the finite verb understands in (29a) and the bare (nonfinite) form of the verb understand in (29b). This putative checking relationship (which we are assuming for the sake of argument, but will reject) is indicated by the red boxes. (We further assume that DPs whose case feature is checked are free to move on to other positions in the sentence.)

(29) a.       b.  
Finite clause, finite verb form Finite clause, nonfinite verb form

Now if verbs were able to check nominative case, regardless of whether they are finite or nonfinite, we would expect the nonfinite verb in the lower IP in (30) to be able to check nominative case on the lower he, on a par with the nonfinite verb in (29b).3

(30) *  
Intended meaning: He claims that he understands Hegel.

However, (30) is completely ungrammatical. We therefore reject the idea that nominative case is checked by V, concluding rather that it is checked by finite I. The contrast between (29) and (30) then follows directly since I is finite in (29) ([pres], does), but not in (30) (to).

The ungrammaticality of (30) isn't due to semantic anomaly, since the intended meaning is both expressible and semantically well-formed, as indicated by the gloss to (30). Neither is the ungrammaticality of (30) due to the split infinitive, since (i) is as ungrammatical as (30).

(i)   *

One might attempt to rescue the idea that nominative case is checked by finite V by replacing (31a) with (31b).

(31) a.   Nominative case is checked by finite I.
b.   Nominative case is licensed by finite V where possible (that is, in clauses that contain a finite V), and by finite I otherwise.

Although there is no empirical argument against (31b), we reject it because it violates conceptual economy. Clauses with finite V invariably also contain a (silent) finite tense element in I, whereas the converse is not true. Moreover, a clause can contain a finite I in the form of a modal, in which case the V is nonfinite. Clauses with finite I thus form a proper superset of clauses with finite V. As a result, (31a) and (31b) are empirically equivalent, but (31b) is unnecessarily more complicated and hence less preferable.

The upshot of the discussion so far is that the head that checks nominative case in English is finite I, and that the licensing configuration for checking nominative case in English is the specifier-head configuration. This is shown in (32) (which supersedes (29)).4 The term 'specifier' is generally abbreviated to 'spec' (read as 'speck').

(32) a.       b.  

Nominative case is not the only case to be licensed in the spec-head configuration in English. So is possessive case, the case-checking head being the possessive determiner ('s or its silent plural variant), as discussed earlier.

In possessive constructions like (i), there are two noun phrases: a lower one (the possessor) and a higher one (the entire noun phrase that contains both the possessor and the thing possessed).

(i)       (ii)  

It is important to keep in mind that each of the two noun phrases has a case feature of its own that needs to be checked. The lower DP has a possessive case feature. The higher DP generally has a nominative or an objective case feature, but it might itself bear a possessive case feature if it is part of an even larger possessive construction, as it is in (ii).

(33) illustrates the spec-head configuration in its general form (YP is the specifier of X, and YP and X are in the spec-head configuration). As is evident, the head X and the noun phrase YP that bear the shared case features to be checked form the endpoints of the path indicated by the red nodes.


Head-spec licensing. A second configuration that licenses case checking is head-spec licensing, which we motivate on the basis of sentences like (34a).

(34) a.   He expected her to dislike him.
b.   He expected that she would dislike him.

In both sentences, what is expected is a state of affairs (= a proposition). Given this semantic parallel, it is reasonable to suppose that the complement of expect in (34a) is the entire italicized sequence her to dislike him (rather than just the noun phrase her). Assuming for simplicity that expect takes an IP (rather than a CP) complement in (34a) gives us the structure in (35) (we treat to as the nonfinite structural counterpart of finite would).


Before addressing our main concern---how objective case is licensed on the embedded subject her, we digress briefly to provide an independent piece of evidence in favor of the structure in (35), which is based on the distribution of expletive there. As the contrast in (36) indicates, expletive there can be the subject, but not the object, of a sentence.

(36) a. ok There was a fly in his soup.
b. * He dislikes there in his soup.

In sentences like (37), however, there is able to appear in immediately postverbal position.

(37)   ok He expected there to be a fly in his soup.

The contrast between (36b) and (37) would be mysterious if there occupied the same structural position in both sentences (namely, the complement position of the matrix verb expected). But the mystery disappears if there is the subject of an IP in (37), just as it is (36a), with the IPs differing only in their finiteness.

Let's now return to our main concern: how objective case is licensed on the embedded subjects in (34a) and (37). Consider the schemas in (38).

(38) a.       b.  
Spec-head licensing Head-spec licensing

Notice that the head-spec configuration in (38b) is the mirror image of the spec-head configuration in (38a), already familiar from (33), in the following sense. In both cases, the case-licensing configuration can be characterized as in (39).

(39)     A case-licensing configuration is defined as follows:
a. a head X
b. the nonterminal node closest to X (i.e., the intermediate projection X')
c. a node closest to X' that is distinct from X
d. the specifier of the node specified in (c)

The difference between spec-head and head-spec licensing simply concerns the direction that the path takes in (39c) (imagine placing a mirror along the X-X' axis in (38a), and you'd get (38b), and vice versa). Spec-head licensing chooses the mother of the head's intermediate projection; head-spec licensing chooses the daughter.

It is standard to refer to the construction in (34a) and (37) as the Exceptional Case-Marking (ECM) construction because it is cross-linguistically rare. Given the analysis that we have just presented, the term is a bit of a misnomer. The construction is exceptional not for reasons having to do to case theory, but because of the rarity (for whatever reason) of V heads that take IP complements and at the same time are able to check objective case. However, because the term is prevalent in the literature, we will use the term "ECM construction" to refer to the construction under consideration and "ECM verbs" to refer to verbs with the two properties just mentioned (IP complements, ability to check objective case).

Given (39), we can say that objective case is checked on the complement subject her by the verb expected in the head-spec configuration.

In the previous section, we presented nominative case as being checked in English in Spec(IP) in the spec-head configuration. If this is so, then subject movement in English can be derived from considerations of case checking. In other words, the subject must move from Spec(VP) to Spec(IP) because nominative case can't be checked in its original position. However, the availability of head-spec licensing opens up the possibility that nominative case is checked in the head-spec configuration, rather than in the spec-head configuration. The case-checking head continues to be finite I, for the reasons discussed in the previous section. If this possibility is correct, then subject movement in English must be derived from considerations other than case theory, such as predication. Given the word order facts of English, it is very difficult to determine which of the two possibilities just outlined is correct. Currently, most generative syntacticians take the position (conceptually odd, because uneconomical) that nominative case is checked in the spec-head configuration, and that subject movement is motivated by considerations of predication.

Head-complement licensing. A third and final case licensing configuration arises in connection with simple transitive sentences like (40).

(40) a.   He expected her.

Here, objective case on her is checked by the verb expected in the head-complement configuration, schematically indicated in its general form in (41).


Notice that the head-complement configuration is a subconfiguration of the head-spec configuration just discussed. This means that a general structural constraint on case licensing, subsuming all three configurations discussed so far, can be formulated as in (42).

(42)     Structural licensing condition:
The nodes in a case-checking relationship as well as the nodes on the path connecting them must be members of a licensing configuration of the form in (39).

The head in a case-licensing relationship always corresponds to (39a). The noun phrase corresponds to either (39c) (head-comp licensing) or (39d) (spec-head licensing, head-spec licensing).

Nonstructural conditions on case licensing. In what follows, we further illustrate the structural licensing condition on case checking in (42), and we introduce three additional, nonstructural conditions on case-licensing: biuniqueness, exocentricity, and matching.

First, consider (43), where we treat their as the spellout of they and possessive 's.

(43) a.   He expected their approval.

In (43), objective case on the higher boxed DP is checked by the verb expected, being licensed by the head-comp relation between them. Possessive case on the lower DP is checked by the possessive morpheme 's, being licensed by the spec-head relation between them. So far, so good.

However, a question that arises in this connection is what rules out (44) (with the same intended meaning as (43)), where the objective case feature on expected checks the objective case feature on them in the head-spec licensing configuration.

(44) *   He expected them approval.

The answer is as follows. Assume a case-checking relationship between expected and the lower boxed DP them. This leaves the higher DP with a case feature that must be checked. Although the higher DP is in a head-complement relationship with expected, it is unable to enter into a case-checking relation with the verb because such a relationship would violate the condition in (45).

(45)     Biuniqueness condition:
Case features on heads and noun phrases stand in a one-to-one relationship.

There is no other structurally licensed head with which the higher DP can enter into a case-licensing relationship. In particular, the mirror image of the head-complement relationship,5 the relationship between the higher DP's silent head and the higher DP itself, is not a possible case-licensing relationship because it violates (46).

(46)     Exocentricity condition:
Case licensing is a relationship between a head and an 'outside' noun phrase (that is, a noun phrase distinct from any projections of the case-checking head).

Finally, (44) is ruled out even if the silent D bears no case feature. This is because D heads that do not bear case features (like a or the in English) don't license specifiers. In other words, there are no elementary trees of the form in (47), which would be needed to derive the higher DP in (44b).


It is worth noting that the biuniqueness and exocentricity conditions we have just laid out have the joint effect that when a head has the potential to enter into a case-licensing relationship with two noun phrases, it must enter into a relationship with the closer one. We can formulate this effect as in (48).

(48)     Minimality condition on case licensing
When a case-checking head has the possibility in principle of entering into a case-licensing relation with two noun phrases, it is the minimal configuration that is the grammatical one.

Thus, we consider the minimality condition as a consequence of the more basic biuniqueness and exocentricity conditions in (45) and (46), rather than as a theoretical primitive.

We can illustrate the effects of the minimality condition on case licensing in connection with German examples like (49). These examples show that the verb kennen `know' and the preposition mit `with' govern the accusative and dative, respectively. (Unbelievable as it may seem, German speakers really do pay attention to the minimal difference between dem and den.)

(49) a.  
den     Mann mit  dem     Hut kennen
the-acc man  with the-dat hat know
'to know the man with the hat'
b. *
dem     Mann mit  den     Hut kennen
the-dat man  with the-acc hat know
c. *
den     Mann mit  den     Hut kennen
the-acc man  with the-acc hat know
d. *
dem     Mann mit  dem     Hut kennen
the-dat man  with the-dat hat know

The schematic structure for all four verb phrases is given in (50).


In (49a), kennen checks accusative case with the higher DP, and mit checks dative case with the lower DP, each in the head-comp licensing configuration (recall from Chapter 4 that verbs are head-final in German, whereas (most) prepositions are head-initial). In other words, as in (43), each head checks the case feature of the DP closest to it. (49b) is ruled out because it violates the matching condition in (51).

(51)     Matching condition:
A case feature on a head and its corresponding case feature on a noun phrase must match in value.

Specifically, even though kennen and the DP would stand in a legitimate licensing configuration (head-comp), the accusative case feature of kennen doesn't match the dative case feature on the higher DP. Moreover, the accusative case feature of kennen is unable to check the matching accusative case feature on the lower DP, because a checking relationship between these two participants would violate the structural licensing condition in (42) (the verb and the lower DP are too far apart). Analogous considerations hold for mit and its potential checking relationships with the lower and higher DPs, respectively.

(49c) is ruled out as follows. Case checking on the higher DP is unproblematic; accusative case is checked by kennen in the head-comp configuration. However, case cannot be checked on the lower DP. Checking accusative case with mit in the head-comp configuration violates the matching condition (dative and accusative don't match), and checking accusative case on the lower DP with kennen violates both the structural licensing condition and the biuniqueness condition on case checking. (49d) is ruled out for analogous reasons.

Case agreement

(coming eventually...)


1. A very small number of German verbs governs a third case, the genitive. We don't discuss these verbs here, because they are felt to be archaic.

2. Note how the -s-less plural of deer, which is exceptional in modern English, goes back to Old English, where it was simply the ordinary plural form for the declension (= word class) to which deer belonged.

3. The structure in (30) is analogous to the structure for its grammatical counterpart, He claims to understand Hegel. Details are discussed in connection with the phenomenon of control in the next chapter.

4. The spec-head configuration is also frequently, though somewhat misleadingly, referred to as spec-head agreement. The reason for this is that subjects and verbs of sentences, which are in the spec-head configuration in the VP, agree in number (the man runs/*run; the men run/*runs). The reason that the term is misleading is that agreement relations don't necessarily imply a spec-head configuration. For instance, determiners agree in number with the head of their NP complement (that woman/*women; those women/*woman), but the D and the N aren't in a spec-head configuration.

5. The relation between the silent determiner and the higher boxed DP in (44) is a mirror image of the head-comp relation in the following sense. The path between the silent determiner and its NP complement involves a first segment from D to D' and a downward turn at D' to give the second segment from D' to NP. Now imagine taking an upward turn at D'. The resulting second path segment ends at the higher boxed DP.

Exercises and problems

Exercise 8.1

A. Using the grammar tool in English case checking, build structures for the sentences in (1).

For the purposes of this exercise, disregard tense lowering.

(1) a.   I waited for her.
b.   I waited for there to be a sale.
c.   It would be convenient for the parents for daycare to be available.
d.   It would be convenient for daycare to be available for the children.
e.   I suspect the class to be difficult.

B. Describe briefly how case is checked on each of the DPs in (1). Feel free to collapse the description of similar cases (!) of case checking.

Exercise 8.2

Assume that heads of different syntactic categories can have different case-checking properties.

A. Using the grammar tool in English case checking, build structures for the noun phrases in (1) and (2).

(1) a. ok the destruction of the city (the city bears objective case)
b. ok the city's destruction (the city bears possessive case)
(2)   * the destruction the city

B. Based on the structures you built in (A), derive the grammaticality contrast between (1) and (2) in terms of case theory.

C. Why is (3) ungrammatical in English?

(3)   * the city destruction
Intended meaning: 'the city's destruction'

D. Using the grammar tool in English case checking, build structures for the phrases in (4).

(4) a. ok fond of the children
b. * fond the children

E. Derive the grammaticality contrast in (4) in terms of case theory. Your answer should include which case is checked on the children in (4a), how you know which case is checked, and which head checks it.

Exercise 8.3

Assume that the case-checking properties of heads of the same syntactic category can vary across languages.

A. Using the grammar tool in German case checking, build structures for the adjective phrases in (1), and explain how case is checked on each of the DPs.

(1) a.  
des     Englischen unkundig
the.gen English    ignorant
'ignorant of English'
der     Regierung  treu
the.dat government loyal
'loyal to the government'

B. In German, case checking on noun phrases within larger noun phrases has undergone change and continues to be subject to variation. The pattern in (2a) was typical of Early New High German (ca. 1300-1600). (2b) is characteristic of modern formal usage and is being replaced by (2c). Using the grammar tool in German case checking, build structures for all three examples.

(2) a. Early New High German  
der     Stadt Zerstörung
the.gen city  destruction
'the city's destruction
b. Modern German, formal
die     Zerstörung  der     Stadt
the.nom destruction the.gen city
'the destruction of the city'
c. Modern German, colloquial
die     Zerstörung  von  der     Stadt
the.nom destruction from the.dat city
'the destruction of the city'

C. Based on your answer to (B), what are the changes in case checking that have taken/are taking place in German? Your answer should include by which heads and in which configuration which case is checked on the DP der Stadt.

D. Based on your answers to this exercise and to Exercise 8.2, compare the way that case in noun phrases and adjective phrases is checked in English and German. Your answer should include by which heads and in which configurations which case is checked in comparable examples in the two languages.

Exercise 8.4

Explain the following grammaticality pattern. Treat his as a spellout of possessive he and 's. You can use the grammar tool in English case checking to help you, but your answer should include more than just the structures for the sentences.

(1) a. ok I would prefer his eating the pizza.
b. ok I would prefer him eating the pizza.
(2) a. ok I would prefer his eating of the pizza.
b. * I would prefer him eating of the pizza.

Exercise 8.5

There are no ECM adjectives in English, as illustrated in (1). Is this absence a statistical accident, or is there a deeper reason for it?

(1)   * I was expectant there to be a problem.

Exercise 8.6

A. Using the grammar tool in Welsh case checking, build structures for the Welsh sentences in (1) (data from Borsley and Roberts 1996:19, 31).

(1) a.  
Gwelai          Emrys     ddraig.
see.conditional Emrys.nom dragon.obj
'Emrys would see a dragon.'
Disgwyliodd Emrys     i  Megan     fynd          i  Fangor.
expected    Emrys.nom to Megan.obj go.infinitive to Bangor.obj
'Emrys expected Megan to go to Bangor.'

B. How is case checked on each of the noun phrases in (1)? (As in English, nominative case cannot be checked in nonfinite clauses in Welsh.) Your answer should include which case is checked by which heads in which specific licensing configuration.

C. Proto-Indo-European (the ancestor of Welsh) is reconstructed as having had rich agreement, and so it presumably had verb raising. The Celtic languages, which are descendants of Proto-Indo-European and to which Welsh belongs, have lost agreement, yet they still exhibit verb raising. Why didn't the loss of agreement lead to the loss of verb raising in Celtic as it did in Mainland Scandinavian?

Problem 8.1

Develop an analysis of case checking that handles verbal gerunds in which the subject of the gerund doesn't receive possessive case, as illustrated in (1) and (2). Make sure that your analysis handles the variability regarding the judgments in (2).

(1) a.   I disapprove of Kim impulsively hiring incompetents.
b.   I'm concerned about there not being time for dinner.
c.   I watched them running down the street.
(2) a. % Kim impulsively hiring incompetents has got to stop.
b. % There not being time for dinner is unfortunate.
c. % Them running down the street is quite a sight.

Problem 8.2

In the text, we list several conditions on case checking: the structural licensing condition (42), the biuniqueness condition (45), the exocentricity condition (46), and the matching condition (51). Is it possible to eliminate at least one of these? For example, is it possible to derive the biuniqueness condition from the structural licensing condition and the exocentricity condition?