In addition to the division in Case theory between structural and non-structural Case, the theory must distinguish two kinds of nonstructural Case: lexical Case and inherent Case. Lexical Case is idiosyncratic Case, lexically selected and licensed by certain lexical heads (certain verbs and prepositions). Inherent Case is more regular, associated with particular θ-positions: inherent dative Case with DP goals, and ergative Case with external arguments. Lexical and inherent Case turn out to be in complementary distribution with respect to θ-positions: only themes/internal arguments may have lexical Case, and only external arguments and DP goals may have inherent Case. This complementary distribution can be accounted for under recent views of vP structure that place both external arguments and (shifted) DP goals outside the VP proper at the point at which nonstructural Case is licensed. Claims in the literature that the more regular datives and ergatives are actually structural Cases are based on faulty or misleading diagnostic tests.