Philosophy and Phenomenological Research

Vol. LXXI, No. 2, September 2005

Fallibilism, Underdetermination,
and Skepticism
ANTHONY BRUECKNEU

University of California, Suntu Barbara

Fallibilism about knowledge and justification is a widely held view in epistemology. In

this paper, I will try to arrive at a proper formulation of fallibilism. Fallibilists often hold
that Cartesian skepticism is a view that deserves to be taken seriously and dealt with
somehow. I argue that it turns out that a canonical form of skeptical argument depends
upon the denial of fallibilisrn. I conclude by considering a response on behalf of the
skeptic.

1. Fallibilism and the entailment principles

Fallibilism about knowledge is the denial of the following entailment
principle:
(KEP) If S knows that p on the basis of evidence e, then e entails p.
Fallibilism about justification is the denial of a related entailment principle:
(JEP) If S has justification for believing that p in virtue of having evidence e, then e entails p.
It would seem that one who holds KEP would do so because of a commitment to JEP, and I will mostly concentrate on E P and its fallibilist deniers
in what follows. JEP is restricted to evidential justification, requiring that S
has evidential justification for believing that p only in virtue of believing an
evidential proposition e that stands in the relation of entailment to p. JEP
leaves it open as to whether S believes that p i f he does, then his belief is
justified; if he does not, then he has justification for believing that p, so that
if he were to come to believe that p (holding all else regarding his epistemic
situation fixed), then he would be justified in his belief that p.
Fallibillists about justification deny E P . Why? There are several problems surrounding JEP to consider. The first concerns cases that figure in
some Gettier-like situations. It seems intuitively clear that S can start with a

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ANTHONY BRUECKNER

justified evidential belief of a true proposition e, infer to a false proposition

that is not entailed by e, and yet have justification for believing that p. For
example, I justifiably believe that everyone in my office is telling me that
Mary will get the job and that these testifiers have been highly reliable, and
so on. I infer that Mary will get the job, and I have justification for my nistaken belief (there has been a clever hoax regarding the job). In general, it
seems intuitively clear that it is possible to hold justified beliefs of false
propositions, as in this example. JEP does allow for this possibility, if there
is such a thing as non-evidential justification. If so, then JEP leaves it open
as to whether one can hold a non-evidentiallyjustified belief of a false proposition. If that is a possibility, then JEP would also allow that one can hold
an evidentially justified belief of a false proposition. This could come about
if one inferred to the mistaken belief that p from false evidential propositions
which (a) are themselves non-evidentially justified, and (b) entail p. Even so,
it seems that JEP makes it too difficult to have a justified belief of a false
proposition.
A second problem for JEP has been emphasized by Jonathan Vogel.
Incredibly, JEP rules out inductively-basedjustification. If S believes that p
on the basis of strong inductive evidence e, then Ss belief is not justified,
according to JEP, since e fails to entail p.
A third problem: according to some philosophers, JEP leads directly to
Cartesian skepticism about justification and knowledge regarding the external
world. It is often said that my perceptual evidence is consistent with the falsity of my belief that, say, I have hands (=h), since this evidence, it is said,
is consistent with the truth of a skeptical hypothesis such as that I am a brain
in a vat whose unveridical experiences are generated by a computer (=SK).
Thus, it is said, my perceptual evidence fails to entail h, since it is possible
that that evidence should be true together with the truth of SK and the concomitant falsity of h. By JEP, on this account, I lack justification for believing h, and I do not know that h if knowledge requires justification.
This line of thought presupposes that my perceptual evidence for h (and
for other external-world propositions that I believe) consists in believed evidential propositions which can stand in logical relations (e.g., consistency,
entailment) to h and SK. The only obvious candidates for such evidential
beliefs are beliefs about my experiences and their connections with external
objects. Many philosophers will reject this view as an over-intellectualization
of the character of perceptual justification. An alternative view would be that
my perceptual experiences themselves, not beliefs about them, constitute my
justification for believing h and other propositions which are believed on the

See Skeptical Arguments (Philosophical Issues 14 (2004)).

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basis of experience.*If we reserve the term evidential justification for justification by believed evidential propositions, then perceptual justification is
not a species of evidential justification, on the view 1 am considering. JEP,
however, only bears on evidentialjustification, as we noted. So, on the nonevidentialist conception of perceptual justification, JEP does not lead directly
to external-world skepticism. Still, one cannot help but think that some principle related to JEP does bear on external-world skepticism.
Again, the intuitive idea in this area is not well-expressed by saying that
my perceptual evidence is consistent with SKs truth, given the non-evidentialist conception of perceptual justification. Neither is it quite right to say
that my having these perceptual experiences is consistent with SK, since
the having of experiences is not a proposition bearing logical relations to SK
and other propositions. It would be better to say: the proposition that I have
these experiences is consistent with SK. This idea links up with a modified
entailment principle for justification:
(JEP*) If j is Ss non-evidential justifier for p, then the proposition that
S has j entails p.
So the proponent of JEP can put forward the sister principle JEP* if he countenances the possibility of non-evidential justifiers. JEP* appears to lead
directly to external-world skepticism, on the non-evidentialist conception of
perceptual justification. The proposition that I have these experiences fails to
entail h, since the proposition about my putative experiential justifier is consistent with SK and with the concomitant denial of h.3
It is worth noting that on one version of the non-evidentialist conception
of perceptual justification, there is a phenomenon that is similar to JEP*s
brand of required entailment relation. It has been held that perceptual experiences have propositional content. Thus, when an experience is said to justify
ones belief that p, we can inquire into the logical relations between the experiences propositional content and the proposition p. On some views, there
can be a relation of entailment here, since in some cases the perceptual content will be identical to ps content. For example, I have an experience
whose content is expressible by That cat is black, and I believe, on the
basis of the experience, that that cat is black. But this phenomenon is irrelevant to the requirement on justification laid down by JEP. It could well be
that my cattish experience is unveridical and my associated belief is mistaken.
2

3
4
5

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See, e.g., Bill Brewers Perception and Reason (Oxford: Oxford University Press, 1999).
Michael Huemers Skepticism and the Veil of Perception (Lanham, M D : Rowman and
Littlefield, 2001). and James Pryors The Skeptic and the Dogmatist (Noris 34 (2000)).
We will see later how this claim might be challenged.
See Brewer, Huemer, and Pryor.
See Brewer, Huemer, and Pryor.

ANTHONY BRUECKNER

In that case, the proposition that I have my putative experientialjustifier fails

to entail the proposition that I believe on its basis. The experience, then,
fails to satisfy JEP*s requirement on justification, even though its content
entails that of the associated belief.
I will digress briefly. Though David Lewis identifies knowledge with the
elimination of alternative possibilities by evidence, his theory bears some
resemblance to JEP*.6 By evidence, Lewis means: ones experience and
memories. So for Lewis, evidence does not consist in believed evidential
propositions. Lewis says that to speak of fallible knowledge, of knowledge
despite uneliminated possibilities of error, just sounds contradictory. My
Lewisian evidence e for p (consider this a non-evidential justifier, in our
parlance) willfail to eliminate an alternative possibility q if there is a possible world in which (1) e is present (and so the proposition that I have e is
true), and (2) the alternative possibility q is true and thus p is false. That
means that the proposition that I have e fails to entail p. So by holding that
knowledge requires Lewisian evidence that eliminates all alternative possibilities, Lewis seems to be endorsing something like:

(KEP*) If S knows that p on the basis of a non-evidential justifier j

(such as Lewisian evidence), then the proposition that S has j
entails p.
However, Lewis in the end is a fallibilist of sorts, since he allows that S
knows that p can be true as uttered in a conversational context even when
Ss Lewisian evidence fails to eliminate an alternative to p that is not relevant given the context. Knowledge-generating evidence is only required to
eliminate all the relevant alternatives.
Back to the main issue of this section: in view of the foregoing problems
for the entailment principles, I would like to join the crowd and sign on to
fallibilism. I reject all the entailment principles: KEP, JEP, KEP*, and
JEP*. I would like to endorse the non-evidentialist conception of perceptual
justification that I have sketched. But since E P * is false, on my proposed
view, there is no simple, direct route to external-world skepticism that is any
longer available via that entailment principle. However, as Stewart Cohen
has emphasized, life is still not so easy for the fallibilist.*

2. Underdetermination and the closure argument for skepticism

Cohen holds that external-world skepticism is still an apparent threat to the
fallibilist in virtue of this widely discussed closure argument:

See Elusive Knowledge (AusfrafasianJournal of Philosophy 74 (1996)).

See Lewis, p. 549.
S e e How to be a Fallibilist (Philosophical Perspectives, Vol. 2 (1988)).
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(1) If I know that h (=I have hands), then I know that -SK(=Z am not a
brain in a vat).

(2) I do not know that -SK.

So, (3) I do not know that h.
Premise 1 is supported by the principle that knowledge is closed under
known entailment:

(CL) If S knows that p, and S knows that p entails q, then S knows that
4.9
How can the skeptic support premise 2?
One approach would be to appeal to Robert Nozicks tracking condition:
(N) If S knows that p, then: if p were false, then S would not mistak-

enly believe that p.

My belief that -SK does not satisfy N: if -SK were false (and hence SK were
true), then I would mistakenly believe that -SK. So given N, I do not know
that -SK. But this strategy for establishing premise 2 is useless to the skeptic, as is well-known. CL is false if N is true, and thus the skeptics rationale
for premise 1 would be defeated.
I think that premise 2 is best seen as undergirded by a principle about justification that we can call the Underdetermination Principle:
(UP) If S has justification for believing that p, and q is incompatible
with p, then Ss putative justifier for p (whether it be evidential or
non-evidential) favors p over q.
Suppose that UPS consequent is false in a given case because Ss putative
justifier fails to favor p over q. Then Ss putative justifier for p underdetermines the choice between p and q, and thus S is not justified in believing p
rather than q. This is the idea behind the principle. Now suppose that the
skeptic can establish

(-F)My putative experiential justifier for -SK does not favor -SK over
SK.

lo

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We can derive premise 1 from CL and the assumption that I know that h entails -SK.
See Nozicks Philosophical Explanations (Cambridge: Harvard University Press, 1981).
See my The Structure of the Skeptical Argument (Philosophy and Phenomenological
Research 54 (1994))for discussion of UP. See also Jonathan Vogels Cartesian Skepticism and Inference to the Best Explanation (Journal of Philosophy 87 (1990)).
ANTHONY BRUECKNER

Then he can use the appropriate instance of UP to show that I lack justification for believing -SK and hence do not know that -SK (supposing that justification is required for knowledge).
What is favoring? If one holds that an experiential justifier is a candidate
for favoring one proposition over another, then favoring is not a logical relation among propositions, since such an experiential justifier is not a proposition. If an experiential justifier favors one proposition over another, then the
justifier makes it more reasonable to believe one than the other.
How can the skeptic establish -F? In a discussion of skepticism, Timothy
Williamson maintains that it is crucial to the skeptic that he make plausible
the following Sameness of Evidence Lemma:
(SEL) One has exactly the same evidence in the good case and in the bad
case.13
The good case is that in which -SK is true and I see that I have hands,
and the bad case is that in which SK is true and I merely seem to see that I
have hands. This principle is of no use to the skeptic in our present context,
though, because we are assuming a non-evidentialist conception of perceptual
ju~tification.~
Still, our skeptic can put forward this Sameness of Just$er
Lemma:
(SJL) One has exactly the same justifier in the good case and in the bad
case.

It seems reasonable to say that -F follows from SJL. Then -F and UP will
yield the result that I lack justification for believing that -SK.
Williamsons reaction to SEL is to deny it: he holds that my propositional evidence in the good case differs from my propositional evidence in the
bad case. Disjunctivists about perceptual experience will make a similar
move in reaction to SJL.I6They hold that experiences are object-involving,
12

13

14
15

16

The reader may have noticed that UP apparently can be used to show that I do not know
that h without relying upon premise 1. The skeptic can maintain that my putative experiential justifier for h does not favor h over SK, so that I lack justification for h (and hence
lack knowledge). I discuss the relation between closure arguments and UP-based arguments eschewing closure in The Structure of the Skeptical Argument. For a reply to
this paper, see Stewart Cohens Two Kinds of Skeptical Argument (Philosophy and
Phenomenological Research 58 (1998)). See also Duncan Pritchards The Structure of
Sceptical Arguments (Philosophical Quarterly 55 (2005)).
See Knowledge and irs Limits (Oxford: Oxford University Press, 2000).
Williamson does not discuss UP and its relation to the closure argument.
For a criticism of Williamsons views on this score, see my Knowledge. Evidence and
Skepticism according to Williamson, (Philosophy and Phenomenological Research 70
(2005)).
See Paul Snowdons Perception, Vision and Causation (Proceedings of rhe Arisrofelian
Society 8 1 (1 980- 1 )).
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in the sense that the perceptual states that I have when seeing a cat and when
merely hallucinating a cat are not tokens of a single perceptual-state-type.
The intrinsic natures of these two perceptual states are determined by the
presence of the cat in the good case and the absence of the cat in the bad case.
As disjunctivists say, there is no common factor between the two perceptual
states. One way of motivating this view is to hold that perceptual states have
propositional content and that when I see a cat, the content of my perceptual
experience is a singular proposition having the cat as a constituent. Whatever we say about the content of the hallucinatory experience, it is clearly
going to differ from that of the veridical experience in the good case on this
conception, for there is no cat in the offing to figure in the hallucinatory
experiences content. Returning to SJL, my putative experiential justifier is
not the same in the good case and in the bad case, on the disjunctivist view,
in virtue of the difference in content between the two states. So SJL is seen
to be false, unavailable to support -F. Thus, the skeptics attempt to use UP
to establish his premise 2 is stymied if disjunctivism is true.
I think that these claims about the metaphysics of perceptual experience
are implausible. But this is not the place to argue the matter. What I would
like to do instead is to look more closely at the interaction between SJL and
UP. To recoup a bit: the skeptic is trying to use U p to show that I lack justification for believing that -SK (and hence do not know that -SK). According
to UP, I will lack justification for believing that -SK if my putative experiential justifier for -SK fails to favor -SK over S K (this is -F). In order to
show -F, the skeptic puts forward SJL. In espousing SJL, the skeptic is calling attention to the (alleged) fact that it is possible that my putative experiential justifier for -SK should be present when SK is true. In other words, the
proposition that I have the putative experiential justifier for -SK is consistent with SK and, concomitantly, with the denial of -SK. In other words, the
proposition that I have the putative experiential justifier for -SK fails to
entail -SK. Sound familiar?
The upshot is that the skeptics strategy of using SJL, -F, and UP to
establish his premise 2 is simply a use of the entailment principle JEP* to
show lack of justification for -SK. But if we are fallibilists and reject JEP*,
then we will fairly reject the skeptics strategy for establishing premise 2.
The closure argument for external-world skepticism then founders, because of
its dependence upon the entailment principle JEP*.

390

See John McDowells Singular Thought and the Extent of Inner Space, in P. Pettit and
J. McDowell, eds., Subject, Thought and Context (Oxford: Oxford University Press,
1986).
ANTHONY BRUECKNER

3. Conclusion
The dialectical situation is rather tricky. I have argued that if the skeptic is
not allowed to make use of JEP* and must accordingly respect the assumption of fallibilism, then he is hard-pressed to find a way of establishing -F
(with an eye towards then using UP to undergird his premise 2). But the
skeptic can protest, All right, if I grant fallibilism, then I cant establish -F
by adverting to SJL. That would just be anti-fallibilism in disguise, the
entailment principle JEP* in disguise. That is, given fallibilism, I am unable
to use UP to show that my putative experiential justifier is not a genuine
justifier by way of arguing: since the proposition that I have the putative
justifier fails to entail -SK (by SJL), the putative justifier does not favor
-SK over SK and so is not a genuine justifier for -SK. Still, I am waiting to
see you, my anti-skeptical opponent, produce a rationale for thinking that the
putative justifier does in fact favor -SK over SK. Otherwise, it will not be a
genuine justifier.
Who wins here? Who loses? If it is true that the skeptic cannot launch his
premise 2 while accepting fallibilism, then that certainly is a strike against
him. But is it then incumbent upon the anti-skeptic to mount an argument to
show F , i.e., to show that my putative perceptual justifier does favor -SK
over SK (and, in general, my putative perceptual justifiers favor believed
external-world propositions over SK)? At this point, the ball seems to be
between the two opponents courts.*

Thanks to Michael Cole for helpful discussions.

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