Mark Newson and
Krisztina Szécsényi

Not so Exceptional Case
Marking in English*

1. Exceptional Case
English Exceptional Case Marking (ECM) constructions involve an accusative
subject in a non-finite clause:
(1)

a

John expects [me to take the blame]

Generative tradition has it that what is ‘exceptional’ here is that the infinitival
subject bears a case which is licensed in the way that objects have their cases
licensed, i.e. by the relevant preceding verbal element1. Thus, these subjects
display certain objective properties. Nominative subjects have their case
licensed from a functional element within the same clause, which, being more
frequent cross-linguistically, is assumed to be non-exceptional.
In the present paper we will present another analysis, from within
Dependent Case theory (DCT), in which the ‘accusative’ case assigned to the
subject of the infinitival clause is not treated as different to the case assigned to
any subject and is therefore not at all exceptional. It will be claimed that all
subjects in English are assigned unmarked case, but for a small number of
elements (five pronouns) this gets realised differently depending on context. But
even from this perspective, an ‘accusative’ realisation is not exceptional.
Indeed, it could be argued that it is the ‘nominative’ realisation that is the
exception, as in most contexts the realisation of a pronoun with unmarked case
is with the ‘accusative’.
In the preceding paragraph the terms ‘accusative’ and ‘nominative’ were
placed within inverted commas to indicate that we will be taking a special view
*

1

We would like to thank Polina Pleshak for helpful comments on a draft of this paper, Irina
Burukina for discussion on its main ideas and the audiences of various talks at which some
bits of the paper have been presented for their questions and comments. We take
responsibility for any remaining errors.
We are being somewhat equivocal in the use of terms here to avoid going into unnecessary
details. As we will not be basing our analysis on Standard Case Theory, we do not want to
take a stance concerning which head is involved with accusative case (V, v, Agro, etc.) and
we adopt the neutral term ‘licensing’ to refer to the relationship between the head and the
DP bearing the case to cover specific ideas such as ‘case assignment under government’,
‘feature checking’, ‘feature valuation’, etc.

The Even Yearbook 15 (2022), Department of English Linguistics, Eötvös Loránd University, Budapest
ISSN 2061-490X, https://doi.org/10.57133/evenyrbk.22ns © 2022, Mark Newson and Krisztina Szécsényi

Not so exceptional case marking in English 51

of such terms. Using such names has often been assumed to be a positive way
to compare and contrast different case systems in the world’s languages. With
their use, for example, we can see similarities between the Hungarian subject of
a finite clause, which carries no case morphology, and the equivalent element
in Japanese, which is marked for case. This is because both languages have a
nominative-accusative system, assigning one case (morphologically unmarked
in Hungarian but marked in Japanese) to grammatical subjects and a different
one to the object (marked in both languages)2.
(2)

a János-
meghív-t-a
János-NOM invite-PAST-3S.
‘John invited Mary.’
b Mari-
alsz-ik.
Mary-NOM sleep-3S.
‘Mary is sleeping.’

Mari-t.
Mari-ACC

(3)

a Inu-ga
mizu-o
no-mu.
dog-NOM water-ACC drink-PRES
‘The dog drinks water.’
b Shojo-ga aru-ku
girl-NOM walk-PRES
‘The girls walks.’

In turn, we can then contrast these languages with those which have an ergativeabsolutive system, such as Basque, where the subject of the intransitive clause
is assigned the same case as the object (absolutive), while the subject of the
transitive gets another case (ergative).
(4)

2

a Jon-ek
sagar bat
jan du.
John-ERG apple a.ABS eat have.(3S.ABS.)3S.ERG
‘John has eaten an apple.’
b Mahai-a
apurtu da.
table-DET.ABS break be.3S.ABS
‘The table broke.’

Baker (2015) claims that Japanese is a marked nominative language, which in his system is
a distinct case system characterised by a negative condition on the assignment of dependent
case (assign dependent case to a DP which is NOT c-commanded by another DP in the same
domain). In such a system, ‘nominative’ is the dependent case and ‘accusative’ is unmarked.
However, while there are languages in which nominative is morphologically marked and
accusative is unmarked, in Japanese both nominative and accusative are marked.

Not so exceptional case marking in English 52

However, we will argue that the use of such case names can also be
misleading in certain instances. English offers a good example. Calling forms
such as he, she, I, etc. nominative and those such as him, her and me accusative
predisposes us to assume that English is similar to Hungarian in having a
nominative-accusative system. However, we will argue that this is not the case
and that English is more like Chinese in terms of its case system, having a
neutral case system in which subjects and objects are assigned the same
unmarked case.
(5)

a Ni/Zhangsan
kanjian wo/Lisi
You/Zhangsan see
me/Lisi
‘You/Zhangsan see(s) me/Lisi.’
b Wo kanjian Zhangsan
I
see
Zhangsan.
‘I see Zhangsan.’
c Wo/Lisi xing
le
I/Lisi
woke.up asp.
‘I/Lisi woke up.’

Our claim is that English and Chinese differ only in terms of how unmarked
case is realised in different contexts: Chinese realises unmarked case in all
contexts uniformly whereas English, for reasons to do with its historical
development, realises unmarked case on certain pronouns differently in
different contexts.
In the next section we will introduce DCT and discuss the difference
between case assignment and case realisation that it allows. Following this we
will present evidence that the subject of the infinitive is assigned unmarked case
rather than the dependent case expected under more standard assumptions. We
will extend the analysis to cover all objects too, meaning that English is a
language which assigns no dependent case to either subjects or objects and
therefore has a neutral case system, as defined within DCT.

2. Dependent Case Theory and the difference between case
assignment and case realisation
Dependent Case Theory (Marantz, 1991; Baker, 2015) is concerned with the
distribution of morphological case rather than the licensing of argument DPs. It
further differs from Standard Case theory in that it assumes that the conditions
of case assignment are determined by the relationships holding between DPs
rather than between a DP and a head. It classifies cases into four types: lexical;

Not so exceptional case marking in English 53

dependent, unmarked and default. We will be concerned mainly with dependent
and unmarked case in this paper.
A core component of DCT sets out the conditions under which dependent
case is assigned. In general terms this can be stated as follows:
(6)

If two DPs, α and β, are contained in the same domain and α ccommands β, then dependent case can be assigned to:
a. α
b. β
(choice of a. or b. parameterised)

The key points here are that dependent case assignment is dependent on the
presence of at least two c-command related DPs within a limited section of a
structure, the domain, which we will discuss a little later. This can be assigned
to the higher (c-commanding) or the lower (c-commanded) DP, depending on
the parametric choice of the language, perhaps relative to the domain. So, it
would be possible for a language to assign a high dependent case in one domain
and a low dependent case in another.
Unmarked case is assigned to a DP which is not assigned a dependent case3.
This means that in intransitive contexts the lone DP will be assigned unmarked
case, alongside the DP not assigned dependent case in transitive contexts: the
subject in accusative languages and the object in ergative languages.
Baker (2015) adds two extra parameter values which allow dependent case
to be assigned to both DPs present in a domain, giving rise to a tripartite case
system, which will not be concerned with here, or to neither of them. This latter
option produces the neutral system in which there is no case distinction between
subjects and objects within the clause.
Turning to the domain, we can see from (6) that one of its functions is to
limit the DPs which determine the assignment of dependent case. So, in (7),
where γ is a domain, dependent case could be assigned in a) but not b):
(7)

a
b

[ … [γ DP … DP ]…]
[ DP … [γ DP …] …]

However, domains are also the determining factor for the assignment of specific
cases. This is because different dependent and unmarked cases are defined
relative to specific domains. For example, at the clause level nominative might

3

Technically, unmarked case is assigned to DPs which are not assigned either lexical or
dependent case, but we ignore the issue of lexical case here.

Not so exceptional case marking in English 54

be the unmarked case, while in the nominal domain, the unmarked case could
be genitive, as suggested by Marantz (1991).
Baker posits that the domain relevant for case assignment is the same thing
as the Spell-Out domain relevant for phase theory (Chomsky 2000, 2001). Thus,
IP, VP and NP4 are taken as case domains. Case assignment takes place at SpellOut and possibly interacts with movement in that the case a DP bears can be
determined after it has moved rather than in its base generated position.
The view that VP is a domain is problematic for some languages in which
subjects and objects interact to allow the assignment of dependent case. If the
object is inside VP and the subject external to it, they should be in different
domains unless the object raises. Indeed, Baker uses the fact that object raising
does affect case assignment in some languages, Sakha for example, to support
his view that VPs are case domains. For those languages where there is no
reason to assume object raising but in which subjects and objects still interact,
Baker suggests that VPs can be ‘soft’ domains, meaning that certain DPs remain
active in these domains even after Spell-Out. In the present paper, we will make
crucial use of the assumption that VP can be a hard case domain.
2.1. The status of cases
It will be useful at this point to consider the status of the notions ‘dependent
case’ and ‘unmarked case’ within the theory and how they relate to specific
cases such as nominative, accusative, dative, etc. Anticipating conclusions
reached a little later, we will refer to the former as ‘cases’ and the latter as ‘case
forms’.
Both Marantz and Baker state that what is actually assigned are case forms.
For Marantz, these amount to features assigned to case morphemes by certain
heads or combinations of heads. Baker sets out the general condition on the
assignment of dependent case in the following way (p. 79):
(8)

If XP bears c-command relationship Y to ZP in local domain WP,
then assign case V to XP.

As this concerns the assignment of dependent case, Baker’s reference to ‘case
V’ must mean different case forms. It seems, therefore, that the notions
‘dependent’ and ‘unmarked’ case are to be seen as labels for types of different
case forms.
4

More precisely, the nominal case domain will be whatever phrase is in the complement
position of the determiner, under the assumption that determiners are phase heads. This
could be any of a number of things, depending on what functional structure and their
organisation one assumes. The issue is not important for the present paper.

Not so exceptional case marking in English 55

However, there is another possible view which seems to exist in the theory.
Marantz states (p. 25):
“ACC is the name for the dependent case that is assigned downward …
ERG is the dependent case assigned upward …”
In other words, accusative and ergative are what we call dependent case
assigned to different positions. This is opposite point of view to the one
presented above. Here, it is dependent case which is the main concern of case
assignment and case forms are merely labels for the different instantiations of
this, determined by the conditions of its assignment5.
If we adopt this perspective, there are only two structural cases assigned in
the syntax. The different case forms would then have to be seen as different
realisations of these. This would work under a late insertion approach whereby
the form selected to realise dependent and unmarked cases is determined by the
context in which the DP is situated (Halle and Marantz 1993).
In effect, this approach separates the two functions attributed to domains:
that of determining the conditions under which case is assigned and that of
determining what specific form DPs bearing those cases take. The former is a
purely syntactic issue and therefore it comes as no surprise that it is constrained
by syntactically relevant notions such as Spell-Out domains. The latter is a post
syntactic matter restricted by some notion of context, which may or may not be
structurally defined. Importantly, the latter does not have to correspond to the
Spell-Out domain.
One argument in favour of this approach is that the domains of case
assignment are not always identical to the contexts of case form realisation. We
will give an example of this a little later, after considering another argument
which points to the same conclusion.
Baker considers the issue of marked nominative and marked absolutive
systems, which show the same case alignments as accusative and ergative
systems but differ in terms of which case is morphologically marked. For
example, in a marked nominative system, the subjects of both transitive and
intransitive constructions bear the same morphological case and the object is
typically unmarked. To account for this pattern, he introduces extra conditions
for the assignment of dependent case (p. 93):
5

A position similar to this is already assumed by linguists who reject the distinction between
‘nominative’ and ‘absolutive’, claiming that these constitute a single case, usually termed
‘nominative’, assigned to the typically morphologically unmarked DP which is not assigned
either accusative nor ergative (e.g. Bitner and Hale 1996). From this perspective ‘absolutive’
is merely the name given to nominative case in the ergative system.

Not so exceptional case marking in English 56

(9)

a Assign NP1 marked nominative if there is no other NP, NP2, in the
same TP as NP1 such that NP2 c-commands NP1.
b Assign NP1 marked absolutive if there is no other NP, NP2, in the
same TP as NP1 such that NP2 is c-commanded NP1.

This not only increases the number of conditions under which case assignment
is determined, but it also adds a different kind of determining principle, as the
principles in (9) involve a negative c-command condition as opposed to the
simple c-command conditions on the assignment of accusative and ergative.
Clearly, by these definitions, marked nominative/absolutive cases in these
systems are dependent and accusative. Correspondingly, ergative are unmarked,
not only morphologically but in terms case type as defined by the DCT system.
They therefore radically differ from the accusative and ergative cases in the
standard systems. Baker argues in favour of this approach, as opposed to one
where there is a simple mismatch between syntactic and morphological
unmarkedness, on the grounds that it allows the two to remain aligned.
However, this argument is seriously undermined by the fact that elsewhere
syntactic and morphological marking are not always aligned. For example, a
language which Baker analyses is Tamil, an accusative language which follows
the usual pattern in having a morphologically unmarked nominative subject. Yet
he argues that genitive is the unmarked case in the nominal domain, despite the
fact that this is morphologically marked. Newson and Szécsényi (2020) analyse
Hungarian as having an unmarked dative subject in inflected infinitives, which
differs from the unmarked nominative subjects of finite clauses by displaying
overt dative morphology. Moreover, some of the examples of marked
nominative languages that Baker himself discusses, specifically Japanese and
Korean, also have marked accusative objects. If these languages assign
dependent case to their subjects, then the object must be syntactically unmarked,
despite being morphologically marked.
It seems therefore that there is no advantage to be gained by complicating
the grammar with additional case assignment principles, such as those in (9).
Assuming that ‘marked nominative/absolutive’ cases are syntactically
unmarked but realised through overt morphology does away for the need of
negative c-command conditions on dependent case assignment, thus producing
a simpler system. This state of affairs is also what might be expected in a system
in which case assignment and case realisation are separate, as we are proposing.
It is arguable that the connection between syntactic and morphological
unmarkedness, although it may be a tendency crosslinguistically, is mainly a
terminological one in DCT. If Marantz had chosen to call the case assigned to
DPs which are not assigned dependent case something other than ‘unmarked

Not so exceptional case marking in English 57

case’, the expectation that it should be unmarked morphologically would have
been diluted.
2.2. Assignment and realisation
As an example of the system we have in mind, we will briefly review the
analysis of Hungarian nominative-dative alternation in Newson and Szécsényi
(2020). The data concern nominative and dative DPs in clausal and nominal
environments. At the clause level, we find nominative subjects in finite clauses
and dative subjects in inflected infinitive clauses:
(10) a … hogy Péter-
that

Peter-NOM

[ lát-ja

a

kutyá-t ] / [ táncol- ]

see-3SG the dog-ACC

dance-3SG

‘… that Peter sees the dog/dances’
b Nem szabad [ Péter-nek lát-ni-a
not allowed

a kutyá-t

/ táncol-ni-a]

Peter-DAT see-INF-3SG the dog-ACC

dance-INF-3SG

‘Peter is not allowed to see the dog/dance’
Within the DP, the same alternation can be found on the possessor, depending
on its position. Possessors in the lower position are nominative and in the higher
position dative:
(11) a

Péter-

kalap-ja / az

én

kalap-om

I.NOM

hat-1SG

Peter.NOM hat-3SG

the

‘Peter’s hat’

‘my hat’

b Péter-nek

a

kalap-ja

/ nekem a

Peter-DAT the hat-3SG

I.DAT

‘Peter’s hat’

‘my hat’

kalap-om

the hat-1SG

As demonstrated in (10), nominative and dative subjects follow the same
unmarked pattern in appearing in both transitive and intransitive contexts.
Clearly, one could not be analysed as dependent and the other unmarked. The
fact that there is no semantic difference between these DPs indicates that one
cannot be taken to be unmarked and the other lexical. The same conclusions
carry over to the nominative and dative possessors.
Assuming that nominative and dative cases are assigned under different
conditions, Newson and Szécsényi argued that the domains of nominative case

Not so exceptional case marking in English 58

assignment must differ from those of dative case assignment. For nominative
case assignment, the domain is the complements of C and D, identified as
canonical heads of extended verbal and nominal projections. The unmarked
dative appears not only in the contexts in (10) and (11), which are differentiated
from the unmarked nominative domains in that they are the complements of the
non-finite agreement, but also in a number of places, such as on certain nominal
and adjectival predicates, which leads to the conclusion that the unmarked
dative domain is to be seen as the elsewhere domain6.
One consequence of this analysis is a proliferation of phases, some of which
seem only relevant for case assignment. However, under the assumption that
there is just one case assigned in these constructions, unmarked case, and that
this is realised by different case forms, there is possibly no need to assume so
many domains. We might assume that there is a single clausal and nominal
phase, in line with standard assumptions, in which unmarked case is assigned.
However, the contexts for realising this case are defined along different lines
and hence different case forms appear. It can be claimed that unmarked case
will be realised as nominative in a context associated with a ‘canonical head’
(HC), such as C and D, and dative elsewhere7. We propose the following
realisation rules for unmarked case in Hungarian:
(12) [unmarked]   / [HC ---]
[unmarked]  nAk elsewhere

3. ‘Accusative’ subjects in English
Newson (2019) argued that the accusative subject of English acc-ing gerunds is
an instance of unmarked case. Following Baker’s (2015) suggestion that the NP
inside the DP is relevant for determining the possibility of assigning dependent
case within the DP and Abney’s (1987) analysis of DP structure, in which the
acc-ing gerund lacks an NP, the most coherent analysis is to take genitive as
dependent and accusative as unmarked.
6

7

Polina Pleshak (p.c.) points out that the notion of an elsewhere domain suggests a link to
default case. However, we take the view of Marantz (1991) that default case is different to
other cases, appearing separately on the case hierarchy. In fact, how default case fits in with
DCT assumptions is not well investigate. But see Newson (2018) where it is argued that
default case occurs only in the absence of an assigned case and unmarked case is assigned.
The notion of an elsewhere domain is strictly to do with assigned cases and is defined as the
set of domains which remains after subtracting those domains identified for the assignment
of specific cases (such as nominative).
This account obviously needs further elaboration, but the present paper is not the place for
this. Its purpose here is to exemplify how we propose to actualise the distinction between
case assignment and realisation.

Not so exceptional case marking in English 59

This, then, raises the possibility that other instances of accusative subjects
are unmarked rather than dependent. With this in mind, consider the accusative
subject of English Small Clauses:
(13) They considered [us aggressive]
The standard view is that these accusative subjects should be analysed as within
an extension of the domain of the governing verb, making the subject the
grammatical object of the verb, as with ECM constructions. However, this is
questionable on the same grounds that such an analysis cannot work for acc-ing
gerunds, as can be seen by comparing (14) and (15).
(14) a This policy made [them nostalgic for a more authoritarian
leadership].
b [Them nostalgic for a more authoritarian leadership]
is a situation to be avoided8.
(15) a We applauded [them voting against the proposal].
b [Them voting against the proposal] was a setback for the
government.
In both cases, as these constructions can appear in subject positions themselves,
it would be hard to account for their accusative subjects as extended objects of
the lower verb from within any framework9. Specifically within DCT, the lack
of a c-commanding DP in the b) examples makes the assignment of a low
dependent case (i.e. accusative) hard to fathom.
Equally as problematic are independent Small Clauses (elsewhere known
as ‘Mad mag sentences’, Akmajian 1984)10:

8
9

10

The use of Small Clauses as subjects was pointed out in Stowell 1981.
Polina Pleshak (p.c.) suggests that in some of these cases the accusative could be licensed
from a c-commanding DP before movement takes place. However, in the examples given in
(14) and (15) it is doubtful that the accusative subject originates in a position where it is ccommanded by a DP and there are other cases where the lack of any other DP demonstrates
that this cannot be the source of a dependent accusative:
i)
Them running away was disrespectful.
ii)
Them free is worrying.
Schütze (2001), assuming a left dislocation analysis for these constructions, argues that the
accusative case on these DP is default. Newson (2018) offers counter arguments.

Not so exceptional case marking in English 60

(16)

a What, me worry?
b Them give me a rise?! Never!
c Him wear a tuxedo?! That, I will have to see!

The lack of a c-commanding DP for the accusative subject in all these
constructions most naturally leads to the conclusion that they are instances of
unmarked case assignment.
3.1. For infinitives
As a step towards an analysis of ECM constructions, let us first turn our
attention towards for infinitives, which share with them an accusative subject
and an infinitive tense.
One main difference between for infinitives and ECM constructions is that
like gerunds and Small Clauses, the former can appear in both subject and
complement positions:
(17) a The government were anxious [for the bill to be passed quickly].
b [For the bill to be passed quickly] is important for the government.
The role of the complementiser as the licensor for the accusative subject has
traditionally been the assumed account of this observation. However, from a
DCT perspective, the traditional analysis cannot be maintained. Having
abandoned the use of head licensing, we cannot assume that the complementiser
has any direct responsibility for the assignment of accusative in this
construction. Given that the subject of the for clause will be accusative whether
it is transitive or intransitive, we are once again led to the conclusion that this is
an instance of unmarked case assignment.
One might wonder why, if the complementiser plays no role in case
marking the subject, is it obligatory?
(18) a * The government were anxious [the bill to be passed quickly].
b * [The bill to be passed quickly] is important for the government.
We can think of several possible responses to these observations, which require
further investigation than is possible in the present context. The most
straightforward of these is to assume that the traditional approach is basically
right and that the complementiser does have a licensing role in this construction.
However, licensing, being divorced from case assignment, does not affect the
analysis of the accusative subject as assigned unmarked case under DCT
assumptions. What is missing, however, is an account of what licensing is.

Not so exceptional case marking in English 61

Clearly, proposals which simply adopt something similar to the Case Filter with
case factored out of the equation, such as Sigurðoson’s (1991) Proper Head
Government Condition, are out of step with minimalist assumptions. But,
Marantz’s (1991) original assumption, that DPs are licensed in argument
positions through a combination of argument structure considerations and the
Extended Projection Principle, is not easily extended to cover the observations
we are examining here. As it is not our intention to devise a theory of DP
licensing here, we will leave the matter at this point.
A second possibility would be to assume that for is not a complementiser
in these constructions, but a preposition taking the accusative DP as its
complement. If this could be defended, then it might be made to follow from
something akin to Marantz’s (1991) suggestion that overt DPs are never
licensed in the subject of an infinitive11. The idea would be that although a DP
would not be licensed in an infinitival subject position, there would be nothing
to stop a PP from appearing in this position. This is probably the least
satisfactory account of the obligatory nature of for. There are numerous
arguments against taking the for complementiser as a preposition (see, for
example, Bresnan 1972 and Huddleston and Pullum 2002), though some of
these might be overcome if we supposed a grammatical function for it, similar
to the treatment of of within the NP. Nevertheless, the parallels that for shows
with other complementisers and the lack of evidence that it forms a constituent
with the following DP make for limited prospects as an account for the data in
(18).
The final approach we will consider is to investigate the conditions on the
distribution of overt complementisers. The ungrammaticalities of (18) may well
have nothing to do with the licensing of the subject in this position, but rather
that the complementiser is required to be overt in its own right. This is suggested
by the fact that finite clauses require overt complementisers when in subject
position, and this does not seem to be a licensing/case issue:
(19) [*(that) the bill was defeated] was a blow to the government’s
economic strategy.
Things are less clear when we consider clauses in complement positions,
however, as here the requirement of an overt complementiser differs for finite
and infinitival clauses. Finite clause complements require an overt
11

Marantz suggested that raising to object account for why ECM subjects are licensed.
However, we will be taking issue with this account and, following Lasnik (2001) will assume
that raising to object is optional and motivated by other considerations when it actually takes
place.

Not so exceptional case marking in English 62

complementiser when associated with nominal but not verbal or adjectival
predicates:
(20) a The fact [*(that) he fell asleep] did not go unnoticed.
b We should have known [(that) he wouldn’t be interested].
c It was possible [(that) no one would notice].
With the infinitive, the pattern differs in that the complementiser is obligatory
with nouns and adjectives, but not always with verbs:
(21) a His demand [*(for) the crowd to disperse quietly] was met with
anger.
b We didn’t expect [(for) that to happen].
c It was essential [*(for) everyone to remain seated].
Again, however, the problem is the lack of a unified account of the distribution
of overt and covert complementisers, without which it is difficult to conclude
about the differences between that and for. As with the theory of DP argument
licensing, it is not our intention to construct a principled account of
complementiser distribution, we just note that such an account may well hold
the key to the data in (18) in a way that divorces the complementiser from the
accusative subject.
3.2. The accusative subject of ECM constructions
Having concluded that the accusative subject in quite a few English
constructions should be analysed as an instance of unmarked case assignment,
we now turn to consider ECM constructions. One reason to think that these
might be different to all the other clauses with accusative subjects is their
distribution. Whereas the other constructions are not restricted to a particular
position, ECM constructions can only appear in the complement of the ECM
verb. Specifically, they are not allowed in subject position:
(22)

a
b

We believed [him to be unavailable]
* [Him to be unavailable] was believed by everyone.

In Standard Case Theory, this observation was accounted for under the
assumption that the subject of the infinitive is dependent on the verbal system
of the superordinate clause for its case. Later approaches, reintroducing Postal’s
(1974) proposals, have argued for a raising to object analysis, in which the
infinitive’s subject raises to the object position of the higher clause for case

Not so exceptional case marking in English 63

marking purposes (Pesetsky 1987, Johnson 1991, Lasnik 1995, Bošković 1997).
Either way, these assumptions ensure that the infinitival clause be in the
complement position of the higher verb. Of course, the same would be true if
we divorce case from licensing and maintain that the subject of the infinitive is
licensed from the verbal system of the higher clause. From this perspective, this
is an issue of licensing, not of case assignment, though it remains to be
established what the details of case assignment are in this case: does the subject
to object movement create the configuration for accusative case assignment or
is accusative case assigned to the infinitival subject before it moves? In this
regard, work by Lasnik (2001) and den Dikken (2018) is highly relevant. These
both conclude that raising to object is optional and therefore we can find the
infinitival subject inside and outside the non-finite clause. Importantly,
irrespective of whether movement takes place or not, the subject appears with
accusative case, from which we can conclude that the infinitive internal subject
position is one to which accusative case is assigned. We will have to go into
further theoretical details to determine whether case is assigned independently
to both positions or whether it is assigned to the subject position and then carried
to the object position when movement takes place. For now, however, we will
be content with the conclusion that the subject of the infinitive is a position to
which case is assigned.
We now face the issue of which case is assigned to the infinitival subject.
On the one hand, given that we have determined that all other accusative
subjects in English are assigned unmarked case, it seems there is reason enough
to assume the same for ECM constructions. On the other hand, there is nothing
immediately obviously wrong in assuming that a more standard analysis is
correct. From a DCT point of view, this would amount to claiming that the
infinitival subject position lies within the same domain as the object of the
higher clause. In other words, the infinitival clause does not count as a case
domain as far as its subject is concerned. This is usually assumed to be because
the clausal complements of exceptional verbs lack a CP, an assumption which
is supported by the facts of raising to object: the lack of the phase head (C)
renders the clause not a Spell-Out domain and therefore its contents only get
spelled out once the next phase head, the v of the superordinate clause, is merged
into the structure. If this is so, the subject of the exceptional clause has its case
determined under the same conditions as the object, whether or not it has raised
to object position.
We therefore have two questions to answer: i) does the subject get assigned
its case only in the subject position or can it also get case after it moves to object
position?; ii) what case is assigned to the subject? These issues are intricately
interwoven and not very easy to answer on empirical observation. We will
return to them after a discussion of the case assigned to English objects.

Not so exceptional case marking in English 64

4. The accusative case of the object.
There is a near universal assumption that English, like all other Germanic
languages, is a nominative-accusative language. This is despite the fact that
virtually all of its nominal elements display absolutely no case marking
whatsoever. The assumption is buoyed up by the observation that most English
pronouns (that is, five out of seven) have differing forms in (tensed) subject and
object positions. The dearth of case morphemes in English was one of the main
reasons for the introduction of the distinction between abstract and
morphological case in the standard theory. This has caused numerous problems
over the years, not least of which is that it necessitates an account of how the
two notions are related, something which has proved to be a rather slippery
subject.
However, the observation that English makes use of the accusative form of
its pronouns to realise unmarked case in the subject positions of virtually all
clauses, except for finite ones, raises a number of flags when considering the
accusative form of objects. If objects are assigned accusative in the standard
way, i.e. as a low dependent case, we have to conclude that English has an
accusative realisation of both unmarked and dependent accusative case. While
this is not ideal, it would be very difficult to argue that accusative subjects are
assigned dependent case as we have pointed out above. It might therefore seem
inevitable to assume that English happens to realise different cases in the same
way.
The consideration of a further issue, however, gives rise to another
possibility which might solve the accumulating number of problems. As
mentioned earlier, Baker’s (2015) claim that case domains are to be equated
with Spell-Out domains means that VP is also a case domain, though for some
languages this could be effectively neutralised by the introduction of the notion
of a soft domain. Let us suppose that English is not such a language and that the
English VP really is a case domain. It would follow from this that objects, being
the sole DP in the VP, would be assigned unmarked case. For the majority of
nominals this is straightforward as there is generally no case marking on English
objects. For the handful of pronouns, however, we would have to claim that they
are assigned unmarked case which is realised by the accusative form. But this
makes pronoun objects no different to pronouns in most other domains, except
for those in finite clauses. From this perspective, the situation is quite
straightforward: pronouns with unmarked case have a special form in the finite
domain, i.e. what is typically identified as ‘nominative’, and a more general
realisation in every other domain, i.e. ‘accusative’.
In terms of case assignment, this view claims that English assigns unmarked
case to virtually all DPs. The one exception to this, as mentioned earlier, is

Not so exceptional case marking in English 65

genitive, which is the dependent case assigned within the nominal domain.
Therefore, it is not totally accurate to say that English has a neutral case system
in the way that Chinese has. However, at clause level, there is a neutral system
in operation. It is certainly not an accusative language.
Within the framework outlined in section 2 of this paper, we claim that
English assigns unmarked case to all DPs at clause level and for the majority of
them this is straightforwardly reflected in the case forms that realise them. For
pronouns, however, there are two case forms which realise unmarked case,
which distribute according to the contextual restrictions in (23). The example is
for the first person plural pronoun, which has the same pattern as most other
pronouns, with some syncretism for a few of them:
(23) 1pl. [dependent]  our
1pl. [unmarked]  we / [CFIN – ]
1pl. [unmarked]  us elsewhere
There is no need to contextualise the realisation of dependent case, as it is only
in the nominal domain that dependent case is assigned. The only
contextualisation needed is for the ‘nominative’ form, which is restricted to the
finite context.
One can see how this situation emerged from what was originally an
accusative system, like other Germanic languages. The loss of case morphology
in English resulted in a mostly neutral case system. For a small subset of high
frequency items, i.e. pronouns, old case forms were maintained as different
realisations of the unmarked case in contexts which partially reflected the
original system. This would not cause a problem for acquisition, as the vast
majority of the data provide evidence for the neutrality of the case system. With
this backdrop, it would not be difficult to spot the few lexical elements with
contextually determined realisations. Indeed, it would be more problematic to
acquire an accusative system, given the data.

5. How exceptional is ECM?
From the above discussion, we can see that even if standard assumptions about
the nature of ECM are valid and that the case of the exceptional clause’s subject
is determined similarly to that of the object, then this is still not very exceptional
as objects are assigned the same unmarked case as most other DPs no matter
which position they occupy. However, there remains a residue of exceptionality
here. Exceptional clauses are generally assumed to lack CPs to allow for raising
movements. This assumption might impinge on how case is assigned to the
subject of such clauses, even if it does not change which case is assigned. It

Not so exceptional case marking in English 66

would be interesting to explore whether even this amount of exceptionality can
be eliminated.
The original motivation for assuming the absence of CP in ECM
constructions, that government from the superordinate verb would be blocked
by the presence of a CP, has no currency in the minimalist approach. However,
evidence in favour of raising to object in such constructions provide another
argument against the CP status of exceptional clauses. The movement of the
subject out of exceptional clauses requires that such clauses not be phases. As
C is a phase head, one way that exceptional clauses can be exempt from phase
status is for the C to be absent.
However, this only holds under one set of assumptions concerning phase
theory. The original system of Chomsky (2000) claimed that the complement
of a phase head is spelled out once the edge of the phrase projected from the
phase head is complete. But Sigurðsson (2002) observed that Icelandic
nominative objects accompanying dative subjects indicates that material inside
transitive VPs is available at the clause phase. This motivated a different take
on the Phase Impenetrability Condition in Chomsky (2001), sometimes referred
to as the weak PIC, in which the Spell-Out domain of one phase head is not sent
off to the interfaces until the introduction of the next phase head. This keeps
open the VP until after the introduction of the next C. Note, however, all things
being equal, this should also keep the domain of the complementiser open until
the higher v is introduced and thus, in principle, allow for raising to object out
of a CP complement. Under these conditions, there would be no need to assume
that exceptional clauses are at all exceptional, leastwise as far as case
assignment is concerned. If exceptional clauses are CPs, then the contained IP
is a case domain in which the subject is determined to be assigned unmarked
case. If it remains in situ, and does not raise to object, it will be realised under
the relevant contextual conditions, which means that if it is a pronoun is will
take the ‘accusative’ form. If it moves, under the claims of Newson and
Szécsényi (2022), specifically that CPs are universally hard case domains, then
its unmarked case will be determined for it within the CP and carried to the vP
internal position. In this position, under the relevant contextual conditions on
realisation, the ‘accusative’ form will once again be selected for pronouns.

6. Conclusion
In this paper, we have attempted to argue that English exceptional case is far
from exceptional in two separate ways. First, it does not involve the assignment
of a different case to subjects of ECM constructions to that assigned to any other
subject, or indeed most other DPs. The view that English has a neutral case
system, at least at clause level, means that all DPs generally are assigned the

Not so exceptional case marking in English 67

same unmarked case. Second, the realisation of the pronoun subject of ECM
constructions as ‘accusative’ is in fact unexceptional, as this is the general
realisation of unmarked pronoun forms adopted in the language. On the
contrary, the nominative realisation of subject pronouns is exceptional from this
point of view, as this form is restricted to a very limited context.
On the way, we have raised a number of questions which remain to be
answered: what is the real nature of DP licensing?; why are complementisers
obligatory in certain contexts?; are exceptional clauses really exceptional in any
way at all? As none of these impinge directly on the issues of case assignment
and case realisation, which has been our main focus, we have not given them
the serious consideration that they require. We leave them as open questions for
the time being.
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Mark Newson
Department of English Linguistics, ELTE
ORCID 0000-0002-7127-6448
newson.mark@btk.elte.hu

Krisztina Szécsényi
Department of English Linguistics, ELTE
ORCID 0000-0003-2192-2157
szecsenyi.krisztina@btk.elte.hu