Editing Case role (section)

=== Fillmore's alternative theory ===
Conversely, Fillmore (1968) suggested that in the case of sentences following the structure of the above examples, the noun phrases are not assigned multiple case roles, but instead retain the same case roles in both sentences (instrument for 'paint', and location for 'wall'). The difference in meaning is attributed to a transformation that takes both identical deep structures and chooses the direct object as it appears in the surface form.<ref name="Fillmore 1968">{{cite journal |last=Fillmore |first=Charles, J. |year=1968 |title=The case for case |journal=Universals in Linguistic Theory |pages=1–88}}</ref>