Evidence from the Lithuanian active existential construction shows that Lithuanian has a type of VoiceP that assigns structural accusative case in the absence of a syntactically projected implicit argument in Spec,VoiceP. This construction violates Burzio’s (1986) Generalization and its later versions (e.g., Marantz 1991, Kratzer 1994, 1996, Woolford 2003, McFadden 2004, Legate 2014). This article offers a revised version of Burzio’s Generalization by proposing that while accusative case must be assigned by a thematic Voice, the assignment of accusative case by Voice may vary independently from the selection of a specifier.

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