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with respect to T5, Soames argues that “[Marcus] can be seen, following Smullyan and Fitch, as implicitly treating proper names as rigid” (Soames 1995, 203). That said, without a possible-worlds semantics, Marcus’ early work does not have the notion of a referent at a world and, thus, cannot be said to have any explicit views concerning rigid designation—reference to just one object across all possible worlds.

      Finally, Soames’ responses to T2 and T6 are much less congenial. With respect to T2—the idea that just because a definite description has been used to fix the referent of a name, this does not mean that the name goes on to carry the meaning of that description—Soames argues that Smith misunderstands Marcus’ (& Kripke’s) work and cites it problematically. To make his case for this, he begins by pointing out that understanding exactly what is behind T2 is somewhat difficult. Because of this, he spends some time trying to spell out exactly what T2 asserts, ultimately claiming that T2 requires holding that:

      (1) “sometimes the referent of a name is semantically fixed by an associated definite description.”

      (2) “even though the description is not synonymous with the name.”

      (3) “if the referent of a name is semantically fixed by a certain description, then being a competent speaker who understands the name will involve knowing that if the name has a referent at all, it must be one that satisfies the description.”

      (4) “if a name N has its referent semantically fixed by a description D, then one who understands the sentence ‘If N exists, then N is D’ will know, without empirical investigation, that it expresses a truth.” (Soames 1995, 199–200)

      

      Unfortunately, Soames claims nothing quite to the level of any of (1)–(4) can be found in Marcus (1961) because “What she was really saying was that despite the fact that recognizing something as a thing presupposes a readiness to apply descriptions to it, nevertheless we have a linguistic device, the proper name, which allows us to refer to a thing without describing it” (Soames 1995, 200).

      As for T6, Soames again argues that Smith has failed to understand Marcus’ and Kripke’s views on the matters at hand. In particular, Soames points out that Marcus could not have introduced the existence of the necessary a posteriori because Marcus fails to use “a posteriori” anywhere in her paper and identifies the necessary with the tautologous, with the analytic. Furthermore, Marcus holds that co-referential proper names are intersubstitutable in all contexts. So, if the following is true—“Krista knows a priori that Hesperus = Hesperus”—so too should the next sentence be true—“Krista knows a priori that Hesperus = Phosphorus.” Given this, Soames says that “it is as clear as anything can be that Marcus did not in her 1961 article embrace the notion of necessary a posteriori identities” (Soames 1995, 205).

      With Soames’ (1995) detailed responses to the particular theses in Smith’s original paper aside, it will also be instructive to look at Burgess’ (1998) responses. This is because Burgess takes a step back to argue that the paper does not just suffer from problems of detail, but also has major problems in its underlying methodology. More specifically, Burgess “begin[s] by listing ten reasons why Smith’s original paper should never have been taken seriously as a contribution to historical scholarship, ten ways in which the paper conspicuously violates elementary rules of historiographical methodology” (Burgess 1998, 125). Here, I will focus on just the first four of these reasons. This is because Burgess is just straightforwardly correct about the last six. That said, admitting this does not undermine the primary goal of Smith (1995a). Rather, it shows that it needs significant work to clean it up. Furthermore, Burgess himself admits that there is an important difference between the first four and the last six when he says “[a]s a result of the four methodological errors just enumerated, Smith approaches the texts asking the wrong question,” whereas the last six simply cause problems of interpretation in answering those questions (Burgess 1998, 127).

      With these preliminaries aside, we move to the list of reasons that Burgess provides for saying that Smith (1995a), the beginning of this saga, never should have happened in the first place. In the order he considers them, the original paper should never have been allowed to be presented because:

      [R1] Smith reduces a complex philosophical theory to a list of a half-dozen points.

      [R2] Smith does not seriously examine Kripke’s work.

      

      [R3] Smith conflates introducing theses with endorsing those theses.

      [R4] Smith uses highly ambiguous labels for the theses under discussion.

      While these are relatively self-explanatory, a few words about each is in order. As far as R1 is concerned, Smith’s reduction of NTR to T1–T6 is problematic because “the importance of a complex theory consists at least as much in the interconnections it establishes among its novel elements” and “it is very far from being [a reasonably accurate enumeration of the novelties of the ‘new’ theory]” (Burgess 1998, 125–26). Furthermore, this list is so problematic because of what Burgess points out in R2—that the list comes from insufficient engagement with Kripke’s original texts. Evidence of the fact that Smith has not significantly examined Kripke’s work is given in the form of the fact that “he omits from his list important novelties of the ‘new’ theory”, including the “notable example [of] the historical chain account of the reference of a name to its bearer” (Burgess 1998, 126).

      Similarly, R3 is supposed to result from the fact that Smith has not only failed to carefully comb the literature after Marcus (1961), but also failed to carefully comb through prior literature. As Soames (1995) pointed out, some of T1–T6 are in fact endorsed by Marcus (1961), but she could not have originated them as she acknowledged following up on work from Smullyan (1947, 1948) and Fitch (1949, 1950). Finally, R4 is meant to draw our attention to phrases from T1–T6 such as “direct reference” and “necessity of identity.” Burgess takes these to be problematic because they are ambiguous and Smith has not checked to be sure that they refer to the same thing when accurately describing a view of Marcus’ and when accurately describing a view of Kripke’s. Again, putting R1–R4 together, Burgess concludes,

      As a result of the four methodological errors just enumerated, Smith approaches the texts asking the wrong question. He simply asks whether there are passages in Marcus (1963) that could be read as endorsements of doctrines to which the labels “direct reference” and “necessity of identity” and so on could be applied. (Burgess 1998, 127)

      Hence, according to Soames (1995) and Burgess (1998),

      (1) Smith (1995a, 1995b) should not have been published in the first place,

      (2) even if their main theses could have been argued for responsibly, these actual attempts would still have methodological problems in arguing through T1–T6 as a stand-in for NTR, and

      (3) even if they did not, the individual attributions of T1–T6 would all be problematic.

      §1.3 Oddities in Soames’ and Burgess’ Responses

      Now that we have sketched the basic contours of this debate, we are in a position to move toward saying something about it. Remember, my ultimate goal is to say that Smith has gotten some things right and some things wrong, with similar claims about Soames and Burgess. I will also argue that part of the explanation for this situation is that all three have had their focus in the wrong place. We should not primarily be concerned with Kripke and we should not be concerned with charges of plagiarism or misunderstanding. Rather, we should be primarily concerned with Marcus (even if occasionally in relation to how much credit she has gotten relative to Kripke). Furthermore, I suspect that, and will argue for the conclusion that, a significant cause of the insufficient amount of credit Marcus has received has been her gender—a social phenomenon. Because of that, we ought to be looking at trends within social groups and institutions, rather than isolated, individual actors. In particular, we will look at the institution of academic philosophy as a whole as culprit and gendered discursive injustice as the charge, which will explain this situation.

      Before we get to that explanation, though, we need to show that there is something

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