Ergative case is said to mark transitive subjects, and it is widely assumed that this is true under the ordinary definition of transitive; however, Bittner and Hale (1996) propose that ergative languages fall into two types, neither of which is based on the ordinary notion of transitivity. In one, a direct object is not necessary for ergative case: any verb with an external argument counts as transitive, following Hale and Keyser 1993 (e.g., Warlpiri). In the other, a direct object is necessary, but not sufficient: the subject gets ergative case only if the object moves out of the VP (e.g., Inuit). This article argues that Niuean, Dyirbal, and Nez Perce are also of this object shift type. A search yielded no language where ergative case is clearly governed only by ordinary transitivity; languages that do fit the stereotype have only ergative agreement. A formal account of the correlation between object shift and ergative case is proposed, under which ergative case can be used as a ‘‘last resort,’’ as one of three ways to avoid the locality violation that object shift creates.

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.

This article provides additional evidence for the universality of Rizzi's (1990) anaphor agreement effect, under which the ungrammaticality of nominative anaphors in English, Italian, and Icelandic is due to the presence of agreement. Languages without agreement are shown to allow nominative anaphors. Objective anaphors cannot be associated with agreement, unless the agreement is a special anaphoric form. Superficial counterexamples to Rizzi's proposal are shown not to be problematic. The relative merits of two formal accounts outlined by Rizzi (1990) are discussed. Finally, it is suggested that the anaphor agreement effect can be a diagnostic for the presence of covert agreement.