Non-restrictive relative clauses behave as if they were not present in syntactic structure in NPI licensing, VP ellipsis, and do so substitution. Since restrictive relative clauses do not show this property, the behaviors of non-restrictive relative clauses present a theoretical problem: how do these clauses merge with their antecedents? We propose that non-restrictive relative clauses merge counter-cyclically. As Epstein, Kitahara and Seely (henceforth, EKS) (2012, 2014) suggest, counter-cyclic Merge produces two-peaked structures, and these explain the invisibilities. Then, we extend the possibilities of counter-cyclic Merge from the point of view of the free Merge hypothesis, and we propose that various types of counter-cyclic Merge apply to other constructions which also show invisibilities.
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