Baker & Vinokurova () argue that the distribution of morphologically observable case in Sakha (Turkic) requires a hybrid account, which involves recourse both to con gurational rules of case assignment (Bittner & Hale , Marantz , Yip, Maling & Jackendo), and to case assignment by functional heads (Chomsky ,). In this paper, we argue that this conclusion is under-motivated, and present an alternative account of case in Sakha that is entirely con gurational. e central innovation lies in abandoning Chomsky's (,) assumptions regarding the interaction of case and agreement, and replacing them with Bobaljik's () and Preminger's () independently motivated alternative, nullifying the need to appeal to case assignment by functional heads in accounting for the Sakha facts.

In an Austronesian-type voice system, one argument is designated the "pivot" in each clause, with verbal morphology indicating the choice of pivot and corresponding changes in case marking and extraction possibilities. It has been suggested that ergativity plays a crucial role in these systems. This paper argues that voice and case reflect separate but interacting systems, which can be dissociated from each other, based on the behavior of voice in Dinka (Nilotic; South Sudan) and Balinese (Austronesian; Indonesia). These languages exhibit familiar voice morphology, but are shown to not involve any ergativity. Instead, we propose that what unifies "voice" system behavior is a lack of structural licensing for subjects in Non-Subject Voices. Different voice systems solve this problem in different ways: Balinese licenses the subject under adjacency with the verb, whereas Dinka allows for a last resort genitive case like in many Austronesian languages of the Philippines and of Taiwan.

<p align="left">In this paper,<strong> </strong>I<strong> </strong>argue that adjacency alone can license a nominal by demonstrating that properties of Balinese PNI are incompatible with either (covert) Head Movement (Baker 2012) or with a bare NP analysis (Massam 2001). The Balinese data are compatible with a scenario in which the nominal head happens to be adjacent to the verb. In this configuration, head-head adjacency licenses the nominal via M(orphological)-Merger (Marantz 1984). Under the proposed analysis, Balinese PNI is a last resort strategy, which vacuously satisfies the Case Filter.</p>

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