Multiple Case Checking

Syntax 2:2, August 1999, 6579
MULTIPLE CASE CHECKING

Susana Bejar and Diane Massam
Abstract. This paper examines Multiple Case Checking (MCC) in raising
constructions in light of minimalist Case theory and an interpretive view of
vocabulary insertion. In general, Case theory excludes the option of a chain receiving
more than one Case. However, certain constructions arguably demonstrate that this is
possible. We present a range of MCC phenomena, showing that they are incompatible
with early insertion models. Inherent Case examples, such as in Icelandic, are
accounted for by markedness. For structural Case examples we present an analysis in
which both Case assignment and Case checking are utilized. We account for aspects of
English, Norwegian, and Niuean MCC using two parameters: whether or not Case
features move along with NPs, and whether or not PF accesses whole chains.
1. Introduction
In this paper we examine certain problems for minimalist Case theory that are
brought to light by Multiple Case Checking in raising constructions, as
previously studied by Massam (1985), McCreight (1988), and Ura (1996). In
general, Case theory has been developed to exclude the option of a chain
receiving anything other than exactly one Case. However, certain constructions arguably demonstrate that this is possible. In particular, Multiple
Case Checking (MCC) seems to force us to posit inflectional feature
complexes that contain seeming contradictions, such as [[+nominative]
[+accusative]]. In this paper we examine these constructions and demonstrate
that presyntactic insertion of phonological features must be abandoned. We
also show that both Case assignment and Case checking are required, and that
languages differ as to which features of a chain are realized phonologically.
The problem of MCC arises only in cases where a single chain receives
more than one Case. If two chains are involved, there is no MCC. For this
reason, we include in our empirical coverage only instances of movement
from a Case-marked position to another Case-marked position.1 We put aside
* We gratefully acknowledge support from SSHRCC (410-97-0493). We would like to thank
Mr. Harry Manamana for his work as Niuean language consultant. We would also like to thank
Jonathan Bobaljik, Jun Mo Cho, Samuel Epstein, Susi Wurmbrand, two anonymous reviewers,
and members of the University of Toronto Syntax Project for useful comments. Any errors are
our own.
1
All MCC data, including the movement cases studied in this paper, are open to an analysis of
prolepsis (Higgins 1981; Wager 1983; Massam 1985), in which two separate chains are posited
with an obligatory coreference relationship holding between them. The problem is, no
satisfactory theory of prolepsis, as distinct from raising, has been developed. There is a danger
that prolepsis analyses might be proposed simply to avoid problematic raising structures, such as
those involving multiple Case. Since at least for the Niuean data presented here, all evidence to
date points to a single thematic chain, we assume that raising is involved in these constructions
(see Massam 1985 and Seiter 1980 for further arguments against prolepsis in Niuean). We thank
Jonathan Bobaljik for discussion on this point. For all the data in this short paper, we rely on the
literature as cited for the basic analyses. We do not attempt here a reanalysis in minimalist terms.
Blackwell Publishers Ltd, 1999. Published by Blackwell Publishers, 108 Cowley Road, Oxford OX4 1JF, UK and
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66
other kinds of multiple Case assignment discussed by McCreight (1988)

because these can be analyzed as multi-chain constructions.2 As can be seen
in the chart in (1), we divide the examples into two groups, based on
empirical behavior. On the left side are MCC raising constructions involving
two or more structural Cases. On the right are MCC raising constructions
involving an inherent and a subsequent structural Case. These are further
subdivided into three subgroups so that the first row contains languages that
freely allow MCC. The second row contains languages that allow MCC but
only under the condition that the relevant nominal be morphologically
underspecified for both checked Cases (i.e., languages that require
morphological syncretism). And the third row contains languages that simply
dont allow a nominal to check Case more than once in the syntax. Note that
we do not look at cases in the inherent-structural group where MCC is
realized syncretically (E) or disallowed (F).
(1)
Structural-Structural
Inherent-Structural
MCC Types
Case Chains
Case Chains
Allow MCC
A. Hungarian, Niuean
D. Icelandic
Allow MCC
B. Norwegian
E. Not examined
with syncretism
Disallow MCC
C. English
F. Not examined
Examples of the first four kinds are given below. The data is
alphabetically keyed to correspond with the typology established in the
chart (AD). Example (2) provides an example of MCC from Hungarian. The
wh-word kiket originates in subject position of the embedded clause, where it
receives nominative Case. En route to its final A-bar position, it checks ECM
(accusative) Case with the intermediate verb. Notice that, morphologically, it
realizes this second Case and not nominative.
(2)
A: Hungarian (from Kiss 1985, as cited in Massam 1985; cf. Chomsky

1981:174)
mondtad hogy szeretnel
ha eljonnenek
kiketi
who-ACC you-said that you-would-like if came(3pl)
Who did you say that you would like it if they came?
Example (3) shows MCC in Niuean. Here the DP na tama originates in the
subject position of the embedded clause, where it receives absolutive Case, as
shown in (3a). In (3b) we see that the DP has raised to a higher position where
2
These include relative constructions where the head bears some relation to two different
Case-marked positions, and coordinate constructions, which can also be analyzed as involving
more than one chain. We also disregard Case-stacking phenomena (e.g., Korean) because it is not
clear that these really do involve multiple Case (Schutze 1997).
Blackwell Publishers Ltd, 1999
Multiple Case Checking
67
it receives middle structural Case. Again, notice that the morphological

expression of Case corresponds to the second checked Case.
(3)
A: Niuean (Seiter 1980; see also Massam 1985, 1996)

a. Manako a
ia ke
momohe [e na tama]
want
ABS he SUBJNCT sleep
ABS pair child
He wants the two children to sleep.
momohe ti
b. Manako a
ia [ke he
na tama]i ke
want
ABS he MIDDLE pair child SUBJNCT sleep
He wants the two children to sleep.
Note that these cases are different from the copy raising cases discussed by
Ura (1996) because no pronominal copy appears in the embedded position
in fact, a copy is generally prohibited (see Seiter 1980).
The B-type examples in (4) show syncretically resolved MCC.
(4)
B: Norwegian topicalization (Taraldsen 1981; McCreight 1988)

a. Peri hadde de trodd [ti [ti ville komme forsent]]
Peter had
they thought
would arrive too late
Peter had thought they would come too late.
trodd [ti [ ti ville
b. {*jeg, *du,
*vi}i hadde de
{*I, *you.sg.NOM, *we} had they thought
would
komme forsent]]
arrive too late
c. {*meg, *deg,
*oss}i hadde de trodd [ti [ ti
{*me, *you.sg.ACC, *us} had they thought
ville komme forsent]]
would arrive too late
hadde de trodd [ti [ti ville komme
d. derei
you.pl.NOM/ACC had they thought
would arrive
forsent]]
too late
You had thought they would arrive too late.
In these Norwegian examples, the topicalized subject of the lowest clause

passes through an ECM position and gets accusative Case. Notice that
although this construction is grammatical when the topicalized DP is a proper
name (as in 4a) it is ungrammatical when it is any of the pronouns in (4b and
4c). The conclusion is that the proper name Per is allowable because it is
morphologically underspecified for nominative and accusative Cases that
is, the same form of the name is used in both nominative and accusative
positions. The first-singular, second-singular, and first-plural pronouns, on
the other hand, are morphologically distinct (or specifed) for nominative and
accusative Case, and neither the nominative nor accusative forms of these
68
pronouns can accomodate the MCC construction. This analysis is confirmed

in (4d) where we see that the second-plural pronoun, which is syncretic for
nominative and accusative Case, is indeed allowable.
MCC is not always allowed, however, as seen in the English example in
(5b). We conclude from the fact that English DPs can raise to a Case-marked
position only from a non-Case-marked position, that MCC is not possible in
English.3
(5)
C: English
a. Mary seems ti to like apples.
b. *Maryi seems (that) ti likes apples.
We have seen examples of all three types of multistructural MCC raising

constructions. The last kind we will consider is quirky-structural MCC.
In the Icelandic passive sentences in (6) we see that when both a quirky
and a structural Case are assigned, the quirky Case must win. In (6a) we see
that the subject argument vi must express the morphologically nominative
form of the pronoun, and the object sjuklinganna receives quirky genitive
Case from the verb. Example (6b) shows that, under passivization, the
derived subject sjuklinganna must still express the quirky genitive Case that
was assigned downstairs and not the structural nominative Case subsequently
assigned upstairs.
(6)
D: Icelandic passives (Andrews 1990, as cited in Harley 1995)

a. Vi
vitjuum sjuklinganna
we(N) visited.1pl the-patients-G.pl.m
We visited the patients.
var
vitja
ti
b. Sjuklingannai
the-patients-G.pl.m. was-dflt visited-supine
The patients were visited.
2. Multiple Structural Case Assignment

Now, consider how these data would be handled by the Minimalist Program
of Chomsky (1995). First, according to Chomsky (1995:241), all features,
including phonological features, are present in the numeration. To take the
Niuean example in (3), this means that the nominal na tama must enter the
numeration with two inflectional morphemes, absolutive and middle, each
3
We do not consider sentences such as (i) to involve raising. Because of the infelicity of (ii)
compared to (iii) we consider that in seems as if sentences, the matrix verb assigns a -role to the
subject.
(i)
Pat seems as if shes in a bad mood today.
(ii) ?Pat seems as if shes absent today.
(iii) Pat seems to be absent today.
69
associated with phonology. Then, the single DP checks two heads one
with absolutive, and the other with middle Case. The Early Insertion
hypothesis is schematized in (7), where each number refers to a formal Case
feature and the cross-mark indicates checking with deletion. In (7a), we see
that the Computational Component (CC) selects two abstract-Case formal
features (FFs) for a single head, each associated with its corresponding
phonology. In the syntax, each of the FFs is checked in turn, as in (7b) and
(7c). We might assume that the FFs are erased by checking as shown in (7),
or that they survive to PF. Either way, remaining at PF will be the phonology
of both morphemes. This result is problematic because it violates the
principle of Full Interpretation (Chomsky 1995), because there is
phonological material which is receiving no interpretation at PF.
2.1 Problems posed by MCCs
(7)
Early Insertion Model (Chomsky 1995)

a. Upon selection
b. Downstairs checking
c. Upstairs checking
d. at PF
It is clear that a revision must be made to this strict model of early

insertion. One possibility would be to develop a late-pronounciation
algorithm that chooses between the two pieces of phonological information
that are being fed to it. We reject this hypothesis on the grounds that it
complicates PF in a stipulatory way and that it is in fact a disguised form of
late insertion. Furthermore, the determining factors for the choice are in fact
syntactic as we will see below. This allows us to maintain that pronunciation
rules are interpretive and do not actively filter structures. Multiple Case
constructions therefore lead us to reject early insertion of phonological
features.
Now we will consider a late insertion analysis. There is lack of clarity in
the literature as to whether Case checking involves named cases (e.g.,
accusative and nominative) or just some general feature of [Case] (as argued
in Legate & Smallwood, in press). If we assume the former, this means that in
cases of MCC, abstract nominative and abstract accusative must both appear
on the noun in the numeration, (as in (8a)), so that each can be checked in
70
turn (as indicated by the check marks in (8b) and (8c)). Again, assuming the
features do not delete, we are left with PF receiving two sets of instructions
(as in (8d)), and we need an algorithm that allows PF to choose which set to
ignore. Under our view that PF is interpretive, this is not feasible.
(8)
Late insertion 1 (= no deletion (with named cases); cf. Halle & Marantz
1993)
a. Upon selection
(no phonological features)
d. At PF
On the other hand, as shown in the schema in (9), it might be assumed that
the features are deleted when checked and do not survive to PF, or that they
are not present at all. In this case, PF will receive no instructions at all as to
how to spell out the Case on the DP.
(9)
Late insertion 2 (= deletion (with or without named cases))

a. Upon selection
(no phonological features)
d. at PF
If PF were to receive no instructions as to which Cases should be

realized, we would be shifting morphological Case assignment theory
entirely to the PF component. This approach has in fact been suggested, by
Marantz (1991) and by Harley (1995). But there are problems with purely
PF Case-assignment theories. We feel that such theories fail to capture the
basic observation that in the majority of situations structural and
morphological Cases are isomorphic and fail to syntactically rule out
Case Filter violations. Therefore, like Schutze (1997), we will continue to
71
assume that there is a relationship between syntactic and morphological

Case.
Following Halle & Marantz (1993), we consider that PF choices or rather
vocabulary insertion (VI) choices are based on markedness considerations,
such that Paninian principles govern the lexical insertion process. However,
_
we claim further
that markedness considerations are the only criteria for VI
choices (other than choices that are parametrically set for the language, as in
(19)). PF has no access to algorithms which decide what the morphosyntactic
features on DPs should be. It can only interpret the morphosyntactic features
fed to it by the syntax. We therefore adopt a weak view of VI in that we allow
it very little power. This is summarized in (10).
(10) Interpretive Vocabulary Insertion Hypothesis
a. The vocabulary item that matches the most features of the node
will be inserted (Halle & Marantz 1993:122).
b. VI is merely interpretive. It cannot choose whether to augment or
suppress morphosyntactic information.
To summarize this section, we have seen that a strict view of checking
plus early insertion leads to a violation of the principle of Full Interpretation
(Chomsky 1986, 1995), as does a late-insertion view if both abstract Case
features survive to PF. If, on the other hand, no abstract Case features are
specified in the input to PF, then we fail to capture the relationship between
syntax and morphological Case. What is needed is an analysis of MCC in
which there are no conflicting features on a single item at PF. In other words,
we want only one feature the right one to survive for PF to interpret.
We now turn to an analysis that yields this result.
2.2 A solution: Checking and assignment
In developing our analysis, we have to keep in mind two facts about MCC.
First, many languages do not allow MCC (for example, English, as in (5)).4
Second, the choice between Cases is not random, nor does it depend on
markedness. Rather, if a DP receives more than one structural Case, the last
one received will be the one that is pronounced. This is seen in (11)(15),
where the second is chosen regardless of which is more marked. We consider
that ergative is more marked than absolutive, and accusative more than
nominative. Note also that following McCreight (1988) and references
therein, we assume that subjects of Latin infinitives get clause-internal
accusative Case.
4
Furthermore, even in languages that do allow MCC, it can be construction specific so that,
for example, Norwegian does not exhibit Niuean-style raising. We assume that other factors such
parameterization of locality constraints, binding, and feature distribution are at work to restrict
MCC phenomena.
72
(11) Niuean, (Seiter 1980)

Raising from absolutive to middle (results in middle; see (3))
(12) Niuean (field notes)
Raising from ergative to middle (results in middle)
a. Manako a
Sione ke
kai he tau tama e
tau
want
ABS Sione SUBJNCT eat ERG PL child ABS PL
apala.
apple
Sione wants for the children to eat the apples.
kai ti e
tau
b. Manako a
Sione [he tau tama]i ke
want
ABS Sione MID PL child SUBJNCT eat
ABS PL
apala
apple
Sione wants the children to eat the apples."
Raising from ergative to absolutive (results in absolutive)
a. Teitei ke
fakatau e
Sione taha fale.
nearly SUBJNCT buy
ERG Sione one house
It nearly happened that Sione bought a house.
fakatau ti taha fale.
b. Teitei [a
Sione]i ke
nearly ABS Sione SUBJNCT buy
one house
Sione nearly bought a house.
Raising from absolutive to absolutive (results in absolutive)

a. Ko e mahani nakai ke
o
e
fanau he aoga?
PRED usual Q
SUBJNCT go(PL) ABS children to school?
Is it usual for the children to go to school?
o ti he aoga?
b. Ko e mahani nakai [e
f
anau]i ke
PRED usual Q
ABS children SUBJNCT go(pl) to school
Do the children usually go to school.
(15) Latin (from Saltarelli 1976, cited in McCreight 1988)
Raising from accusative to nominative (results in nominative)
Homerus traditur caecus
fuisse
H(NOM) is-said blind(NOM) to-be(PER)
Homer is said to have been blind.
In Niuean, as seen in (3) above, when raising from absolutive to middle
both structural cases the latter gets expressed. Similarly, as in (12) when
raising from ergative to middle, middle gets expressed. This could be consistent
with the hypothesis that the most marked structural Case wins, but notice in
(13), which exhibits raising from ergative to absolutive, that absolutive (the
least marked structural Case) wins. Facts like (13) lead us to propose that in
multistructural MCC constructions, the upstairs Case, not the most marked
Case, wins. Example (14) is included for completeness. In (14) we see
absolutive checked both downstairs and upstairs. This is not a critical case,
73
except that it shows that the same structural Case can be checked twice. Finally,
the Latin example in (15) shows that in raising from accusative to nominative
the last checked Case wins, regardless of markedness.
We now turn to an account of these facts. In general, we assume the
Minimalist Program, as in Chomsky 1995, except where specified. We
propose that among the languages we are considering, Case is unique and that
at all levels of grammar, a DP may only bear one Case feature. Given this
restriction, we propose a theory of Case that is a combination of Case
checking and Case assignment.5 DPs enter the numeration with simply a
[Case] feature. Relevant functional projections, however, are entered with
[Case] and with a named feature as well, such as [acc] or [nom]. When a DP
checks Case against a functional head, automatically [Case] is checked, and
[nom] or [acc] is copied or assigned as a subscript on the Case feature of the
DP by the functional projection. Both checking and assignment must be
satisfied for convergence. As we will see, PF either implements the head of
the A-chain or the whole A-chain. A schematization of this proposal is given
in (16) where (c) and (d) show the representations fed to PF.
(16)
a. Infl pre-checking
INFL
j
CASEnom
c. Infl post-checking
INFL
j
CASEnom
b. DP pre-checking
DP
j
!
CASE
d. DP post-checking
DP
j
CASEnom
Given this, let us now consider English. If a DP were to raise from a Casemarked position, possibly attracted by a Case feature on a higher Infl, the
assigned Case would move, along with the DP. This Case would block further
assignments because the morphosyntactic Case slot is unique.6 This is not to
say that such an instance of Attract would not be possible, but the derivation
would not converge because the Case feature on the higher Infl would not be
properly checked. Thus, in English, MCCs are ruled out.
Note that Chomsky (1995) also rules out raising from a Case-marked
position to another Case-marked position by his claim that [Case] on a noun is
deleted or erased once checked. This would mean that in a sentence such as (5),
the Case feature on the matrix Infl would remain unchecked, and the derivation
5
Many other researchers on Case have been led to the conclusion that Case consists of more
than one component, often including, for example, morphological and abstract Case. Our
proposal belongs to this family of ideas.
6
Because this is a hypothetical situation, it is difficult to determine whether a copy of the Case
subscript remains on the trace. In principle, for the issues at hand, the exact nature of the trace is
irrelevant.
74
would crash. In our view, the [Case] feature itself does not become inert, but
because the assignment subscript slot is filled, it effectively does, because the
DP cannot in fact check further Cases.
Now let us look at situations where MCC does occur. Clearly, in these
instances, a Case assigned in a lower position does not block further Case
assignment. How can we permit this situation? We propose that in such
constructions the specific Case of the DP is interpretable only by virtue of being
in a checking configuration with that functional head. This assumes that the
interpretability of Case features requires that they be dominated by an
appropriate functional head. In other words, Case is interpreted
compositionally. Effectively, this means that the Case subscript is left behind
when the DP moves out of one Case-checking configuration into a higher one,
as in (17b). Thus it is eligible to receive a different case specification. This is
the sort of derivation we propose for Niuean. The structures in (17) demonstrate
this with a nominative/accusative system for simplicity.
(17) a. Checking downstairs [nom]
IP
Vmax
VP
[nom] configuration
IP
DPi
Vmax
Infl
CASE
[nom] CASE t
i
[nom]
VP
b. Checking upstairs [acc]

IP
Vmax
DPi
V+v
CASE
[acc] CASE
[acc]
[acc] configuration
VP
IP
ti
Vmax
Infl
CASE
[nom] CASE t
i
[nom]
VP
75
The fact that the embedded Case was assigned is recoverable to the
grammar by its visibility on the trace left behind.7 Because it is on an empty
category, it will not be pronounced, but it can be attested in other ways for
example, by the agreement on the lower verb in the Hungarian example in
(2).8 We assume that wh-chains have access to the head of their A-chain at
PF, in order to account for the fact that wh-words bear the Case assigned to
the head of their A-chain.
Now lets consider syncretic cases, like the Norwegian examples in (4).
Here, MCCs are permitted just in case there is no morphological conflict
between the assigned Cases. This fact tells us that in this language, like
Niuean, it is syntactically possible for a chain to have more than one Case.
However, for Norwegian, we propose that all Cases on the chain are
simultaneously accessible at PF, as in (18a). In particular, this means that at
PF, the chosen vocabulary item must be consistent with each position in the
chain, where consistent with means that the Case value of the item must
not be distinct from any Case value in the chain. Crucially, we assume that
the lack of a Case value on the foot of the chain is not considered distinct,
thus allowing English examples such as (5a). In Niuean, on the other hand, as
in (18b), only the head of the chain is spelled out. Given this, it is at the level
of PF that we need to rule out sentences such as (4b,c). Recall that PF accepts
only unambiguous instructions. In Norwegian, instructions such as firstsingular [+nominative and +accusative] will simply not be able to undergo
VI, because there is no matching vocabulary item that is consistent with every
position in the chain, as defined above. Instructions such as Name
[+nominative and +accusative], however, will be interpretable at VI;
consistency is met, because the relevant vocabulary item is underspecified for
Case.
(18) a. Norwegian-type language
[IP. . .DPi [Vmax V+v. . .[[IP. . .ti. . .[Vmax. . .[ti. . .V]]]]]
j
j
j
Case
Case
Case
[acc]
[nom]
PF instruction: Spell-out chain (VI: [+nom, +acc])
b. Niuean-type language
[IP. . .DPi] [Vmax V+v. . .[[IP. . .ti. . .[Vmax. . .[ti. . .V]]]]]
j
j
j
Case
Case
Case
[middle]
[abs]
PF instruction: Spell-out head of chain (VI: [+middle])
7
We adopt the minimalist notion of trace, which holds that traces are in fact unpronounced
copies, but we use the term trace to avoid confusion with pronounced pronominal copies.
8
We assume that nominative Case and agreement are crucially intertwined.
76
At the level of PF, English is like Norwegian in that it spells out the chain,
but in English conflicting Case information in a single chain can never arise, as
discussed above. The range of language types discussed is represented in (19).
(19) Case and chain typology
Take Case
Spell-out Chain
English
Norwegian
Niuean
+
+
The unmarked setting for each parameter in (19) is indicated by [+]. This
typology is consistent with views of learnability, based on the familiar type of
positive-evidence arguments. With respect to the Take Case parameter, English
exhibits the unmarked case, whereas both Norwegian and Niuean instantiate
the marked case. Learners of the latter languages would be presented with
positive evidence for the marked value of this parameter, because these
languages allow chains to grammatically bear more than one Case.
Now consider the Spell-out Chain parameter. Norwegian and English
exhibit the unmarked situation for this parameter, where the entire chain
feeds to PF. Niuean exhibits the marked situation, where only the head of the
chain feeds to PF. It is only in Niuean that the learners would receive positive
evidence as to which Spell-out parameter is required, because they hear
sentences where the case of the NP does not match the case assigned to its position. Note that once the structure of these sentences is determined, the
child is automatically led to a [] value for the Spell-out Chain parameter.
Consider now ?-type languages. In fact, such languages would not differ
empirically from English, but we predict that such a type would never be
attested: Because the two language types are empirically nondistinct, the
child will always opt for the unmarked Spell-out parameter value and spell
out the whole chain.9
So, it appears that syncretic MCC constructions are constrained, not only
in the syntax, but also at VI, because PF can choose to spell out either the
whole chain or the head of the chain. In the Norwegian case, the Interpretive
Vocabulary Insertion Hypothesis is obviously respected in that instructions to
VI must be unambiguously interpreted. In the Niuean case, where a choice
does appear to be made at PF as to which Case to pronounce, there is no
violation of the Interpretive Vocabulary Insertion Hypothesis, because this
choice is a parameter set during acquisition and does not vary from derivation
to derivation.
Sam Epstein (personal communication) has pointed out that this constitutes an example of a
language which is provided by UG, but which is not learnable, thus supporting Chomskys claim
(1995:18) that all grammars provided by UG need not be learnable.
77
3. MCC and Inherent/Structural Case

Finally, lets look at the well-known cases of MCC where one Case is
inherent. One example is that of Icelandic quirky Case under passive, which
we saw in (6).
It is clear from McCreight (1988) that markedness is involved in this type
of MCC resolution. We can build markedness into our checking theory by
assigning quirky Cases a hierarchical structure that is dominated by a [Case]
feature, as in (20).
(20). a. Nominative
CASEnom
c. Accusative
CASEacc
b. Quirky subject
CASEnom
j
dative
d. Quirky object
CASEacc
j
dative
The actual [Case] node of the quirky argument can itself be used to check
a higher structural Case feature. In (6b) we assume the verb assigns its
underlying object a marked quirky Case. Then, when it raises to subject
position, its root [Case] node will enter into a checking relation with Infl, the
result being like (20b). Because inherent and abstract Cases are different
types, it is possible for both to appear in a single Case slot. At VI, basic
Paninian principles, as outlined by Halle & Marantz (1993) will ensure that
the_ more highly specified Case (i.e., the quirky Case) is realized. This means
that a DP with a quirky Case and a structural Case will be phonologically
realized with the quirky Case. The fact that verbs fail to agree with quirky
Case arguments can be accounted for if agreement is a reflex of the operation
of vocabulary insertion on nominative Case.
The possibility for nominative and dative to both be assigned to a single
DP supports our view that structural Cases are not true optional features (in
the sense of Chomsky 1995) but rather are assigned values for features, rather
like subscripts on a Case feature.
The shape of the hierarchy thereby determines what feature combinations
are licensed in the grammar. It rules out two structural Cases, except in
languages where Case assignment is configurational, and it allows for quirky
plus structural combinations. Thus, feature hierarchies such as those proposed
by Ritter (1997), Harley (1994), and others, are relevant to syntax as well as
morphology.
Notice finally, that covert Case checking is rendered impossible under our
analysis because Case would not yet be assigned at PF. But note that covert
Case checking is virtually impossible in all models in which morphological
78
Cases are determined at PF because, in order for PF to compute which case to

insert, it has to reiterate the covert movement within the LF component.
Because it remains an open question whether covert Case checking does
exist, we leave this issue aside.10
4. Conclusion
In conclusion, our analysis of MCCs postulates the following:
Early insertion models are problematic in the face of MCC data.

VI is constrained by (10): it cannot choose between features; otherwise
we would expect the most marked feature to win always, which is not
the case in multistructural MCCs.
Covert Case checking is impossible.
There are constraints on crosslinguistic MCC variation. It is disallowed
if Case assignment is indelible; it is subject to markedness in the Case
of inherent-structural MCC; it is permitted in instances of
compositional Case assignment but is allowed only syncretically if a
language executes VI with reference to all features of a chain.
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Susana Bejar
University of Toronto
Department of Linguistics
130 St. George St.
Toronto, ON M5S 3H1
Canada
sbejar@chass.utoronto.ca
Diane Massam
University of Toronto
Department of Linguistics
130 St. George St.
Toronto, ON M5S 3H1
Canada
dmassam@chass.utoronto.ca

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Syntax 2:2, August 1999, 6579