UNLUCKY GETTIER

CASES
by
JIM STONE
Abstract: This article argues that justified true beliefs in Gettier cases often are
not true due to luck. I offer two unlucky Gettier cases, and its easy enough
to generate more. Hence even attaching a broad anti-luck codicil to the
tripartite account of knowledge leaves the Gettier problem intact. Also, two
related questions are addressed. First, if epistemic luck isnt distinctive of
Gettier cases, what is? Second, what do Gettier cases reveal about knowledge?

Luck is considered essential to Gettier cases. As Stephen Hetherington

(2005) writes:
What is most distinctive of Gettier cases is the luck they contain. Within any Gettier case, in
fact the well-but-fallibly justified belief in question is true. Nevertheless, there is significant
luck in how the belief manages to combine being true with being justified.

Heres the sort of case Hetherington has in mind (call it Sheep-Shaped

Rock 1). I see a rock that erosion has carved into a sheep shape, so I
justifiably believe a sheep is on yonder hill. Coincidently a sheep is grazing
behind the rock. Here justified true belief is insufficient for knowledge. As
Duncan Pritchard writes: The standard diagnosis of these examples is that
they show that merely true belief supported by good reflectively assessable
reasons would not suffice to ensure knowledge because such reasons would
not be sufficient to rule out epistemic luck (2005, p. 151). My beliefs
justification consists of the good reflectively assessable reasons that
support it.
We might try to avoid Gettier cases, therefore, by adding a general
anti-luck codicil to the tripartite account of knowledge (namely, that
knowledge is justified true belief). Some sorts of luck are benign,
however (Unger, 1968). That I witness a crime because I chanced to walk
Pacific Philosophical Quarterly 94 (2013) DOI: 10.1111/papq.12006
2013 The Authors
Pacific Philosophical Quarterly 2013 John Wiley & Sons Ltd & University of Southern California.

PACIFIC PHILOSOPHICAL QUARTERLY

home a new way is epistemically harmless. Pritchards concern is

the veritic luck that exists when it is a matter of luck that the agents
belief is true (2005, p. 146). Veritic luck is at issue in Gettier counterexamples, he maintains (p. 148), and the way to avoid them is to identify
an external epistemic condition which ensures that the agents true belief
cannot be acquired in a veritically lucky fashion (p. 151). Satisfaction of
this condition entails the target propositions truth and also that the
belief in question tracks the truth across the relevant nearby possible
worlds.
Which external epistemic condition? Robert Nozick (1981) maintained
that Ss true belief p is knowledge just in case S would not have believed
p if p had been false (sometimes called the sensitivity condition) and
would have believed p anyway if p had been true in a somewhat different
way or under somewhat different circumstances (Ss belief adheres to
ps truth; more about this later). Knowledge is true belief that so tracks
the truth (p. 178) that is, the belief satisfies both the adherence and
sensitivity conditions. Nozicks account of knowledge is defeated by
unlucky Gettier cases (see Section 4, below), however it can still be
deployed as an anti-luck constraint.1 However Pritchard strongly favors
a safety condition: roughly, if I know contingent proposition P, then, in
nearly all nearby possible worlds in which I form my belief in the same
way I form it in the actual world, I only believe P when P is true (2005,
p. 163).2
Happily, theres no need to decide the competition. Lets secure a strong
anti-veritic luck constraint by conjoining safety with truth-tracking (which
is itself a combination of sensitivity and adherence). I submit that robust
relations of mutual counterfactual dependence between my belief and its
truth-maker intuitively preclude my beliefs being true by luck or coincidence.3 Note that in SSR 1 my belief that a sheep is on the hill satisfies
neither conjunct of the constraint, but my present belief that Im typing on
a computer satisfies both. If this strong anti-luck constraint (sensitivity
and adherence (which together constitute Nozickean truth tracking) plus
safety) doesnt rule out the Gettier cases I will offer, no part of it will
exclude them.
In what follows, I will argue that justified true beliefs in Gettier cases
often are not veritically lucky. I offer two unlucky Gettier cases, and its
easy enough to generate more. Hence ruling out veritic luck doesnt avoid
all Gettier cases. Pritchard, however, points out that epistemic luck also
includes an internalistic sort of luck, reflective epistemic luck. I will show
that Gettier cases generally do not involve reflective epistemic luck, either.
Therefore epistemic luck is not what is most distinctive of Gettier cases.
This raises two related questions: First, if epistemic luck isnt distinctive of
Gettier cases, what is? And, second, given unlucky Gettier cases, what do
Gettier cases reveal about knowledge?
2013 The Authors
Pacific Philosophical Quarterly 2013 John Wiley & Sons Ltd & University of Southern California.

UNLUCKY GETTIER CASES

1.

An unlucky Gettier case

We add a wrinkle to SSR 1 (call this new example SSR 2). Unbeknownst
to anyone, the county through which Im hiking is infested by a breed of
shy sheep whose keen senses detect approaching human observers. These
sheep hide behind anything big enough to hide them, but they favor rocks.
As sheep in this county have always vastly outnumbered rocks, from time
immemorial sheep are lined up several deep behind every rock big enough
to hide a sheep. Also, rocks in this area occasionally shift position due to
earth tremors. Especially they tend to roll down hills. Call this world A
(for actual).
As the closest possible world (w) where the hill is sheepless resembles
A in the above respects, in w the sheep-shaped rock I see in A has rolled
down the hill. Otherwise sheep would be hiding behind it on the hill. So
in w I see neither sheep nor rock. Hence the sensitivity condition is satisfied: I wouldnt have believed a sheep was on the hill if none had been
there.
Nozicks adherence condition is unsatisfied, however. He writes of
this condition that not only does S actually truly believe p, but in the
close worlds where p is true he also believes it; the subject believes
that p for some distance out in the p neighborhood of the actual world
(1981, p. 176) Now moving some distance out, but remaining close to
the actual world, there is a world where the rock behind which the sheep
hides isnt sheep-shaped. I apply the same epistemic method in that
world looking at that very hilltop and do not believe a sheep is on it.4
As the adherence condition is unsatisfied, so is our strong anti-veritic
luck constraint.
A new feature must be added to our example (SSR 2 will henceforth
denote this amended version). An ancient tribe of sheep-idolaters secretly
peoples the unexplored region through which Im trekking. They chisel all
appropriately sized rocks on hilltops into perfect facsimiles of sheep. Consequently the hilltops are peppered with sheep-shaped rocks with sheep
hiding behind them. These sheep are paranoid a breed-wide neural
artefact of their genetically-determined morbid shyness. Consequently
they hide only behind sheep-shaped rocks, since they distrust other rocks.
Moving some distance out, but remaining in the neighborhood of the
actual world, there is no world where a sheep (perhaps of another color or
gender) is on yonder hill but the rock I see on the hilltop isnt sheepshaped. (Note that neither the rock nor its shape is caused by the sheeps
presence, nor are the rocks representations of particular sheep.) Is there a
close-in world where the sheep-shaped rock is obscured by trees or other
rocks? A basic tenet of the idolaters religion is that nothing should
obscure the view of a sacred rock; long ago they removed all obstructions.
Consequently the adherence condition is satisfied.
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Pacific Philosophical Quarterly 2013 John Wiley & Sons Ltd & University of Southern California.

PACIFIC PHILOSOPHICAL QUARTERLY

What about the safety condition? My belief that a sheep is on the hill is
true in the closest worlds to A where I arrive at it in the way I actually did,
namely, by looking at that hilltop. For in nearly all nearby worlds where
I arrive at my belief in this way, I see a sheep-shaped rock that hides a
sheep. As my justified true belief satisfies the safety, adherence and sensitivity conditions, it satisfies our strong anti-veritic luck constraint.
Nonetheless SSR 2 is a Gettier case. For I know nothing about any of
this. I believe a sheep is on the hill because Im making a knowledgenullifying mistake, namely, mistaking a rock for a sheep. If I learned I was
looking at a rock, not a sheep, I would judge that I didnt know what I
thought I did. Since the falsehood that I see a sheep on the hill is my whole
reason for believing one is there, as the first belief plainly isnt knowledge,
neither is the second.

2.

Mistakes and knowledge-nullifying mistakes

Lets say I make a mistake when I take one thing for another, where
thing covers objects, like rocks, and particular situations, like particular
parallel lines being equal in length. Paradigmatic mistakes flow from
immediate sensory inputs, but this can be extended to include false testimony and inductive evidence about what will soon happen. It is required
of a mistake, as I will use the term, that it consists at least partly in a
cognitive change in the makers mind. When I mistake a rock for a sheep,
for instance, I come to believe that I see a sheep. When I reach into a box
of Sure Fire matches, convinced by strong inductive evidence that striking
Sure Fire matches always causes them to light, the cognitive change is
coming to believe that striking this particular match (the one I now grasp
in my hand) will cause it to light.
Part of what is required for my belief that p to be based on a mistake,
as I will use the term, is that the cognitive change (c) in which the mistake
partly consists is part of my beliefs cause. Also required is that the
causation involves a cognitive process by which c is part of my reason for
my belief.5 In standard Gettier cases, the mistake closely precedes the
beliefs formation, perceptual and testimonial contexts being the natural
habitat of Gettier cases (as mistaking a rock on the hill for a sheep is at
least a near-proximate cause of my believing that a sheep is on the hill).
By way of definition, to say a mistake upon which my belief is based is
knowledge-nullifying is to say that, if Im rational and I come to think my
belief is based on my making the mistake, I would for that reason seriously
doubt my beliefs truth. Seriously signals the doubt is stronger than mere
skeptical doubt; note that knowledge doesnt occur in the definiens. In
SSR 2, if I came to believe that I had mistaken a rock for a sheep, I
wouldnt even believe a sheep is on the hill. Suppose, on the other hand, I
2013 The Authors
Pacific Philosophical Quarterly 2013 John Wiley & Sons Ltd & University of Southern California.

UNLUCKY GETTIER CASES

know that sheep are hiding behind every sheep-shaped rock. Then the
mistake would not be knowledge-nullifying: I know that, even if somehow
Im seeing a rock, a sheep is behind it. So, if I learned my belief is based on
that mistake, I would not doubt a sheep is on the hill. Mistakes neednt
nullify knowledge. Note that I make the same knowledge-nullifying
mistake in SSR 1, which is sufficient to explain why it isnt knowledge.

3.

Is SSR 2 reflectively lucky?

Pritchard, recall, maintains that epistemic luck includes an internalistic

sort of luck. I suffer from reflective luck when my belief that P is true in
the actual world, but P is false in many of the nearest possible worlds
where these worlds are ordered solely in terms of what Im able to know by
reflection alone in the actual world (2005, p. 175). That is, given what Im
able to know by reflection alone, its a matter of luck that my belief is true
(p. 175). For example, suppose I believe P on the basis of reliable clairvoyant powers that I disbelieve I have. In fact, I have no reason to think
I have them and good reason to think I dont. Given what I know by
reflection alone, therefore, theres no reason to take my believing P to be
anything more than a groundless hunch. Let S be the set of the nearest
worlds consistent with what I know by reflection alone; these are the
worlds that matter in estimating reflective luck. My belief that P is false in
most of these nearby S-worlds, since groundless beliefs are highly unreliable in the actual world. So my true belief that P, though not veritically
lucky, suffers from reflective epistemic luck.
Pritchards talk of reflective luck is meant to flesh out what it is for a
belief to be supported by good reflectively assessable reasons. My belief is
so supported if and only if, given what Im able to know by reflection
alone, it is true in most nearby worlds where it is formed in the way I
believe it is in the actual world. As every Gettier-case belief is supported by
good reflectively assessable reasons, no justified true belief in a Gettier case
is reflectively lucky.
In evaluating our reflectively assessable grounds for a particular belief,
Pritchard points out that we implicitly bracket fundamental skeptical
hypotheses, or, perhaps better, consider them true only in distant worlds
(pp. 2078). If memory, perception and induction are all questionable, I
havent enough reflectively assessable knowledge to justify any contingent
belief about the external world. So good reflectively assessable reasons can
advert to the world, to the deliverances of memory, induction, to the
testimony I have reason to consider reliable, and so on.
Concerning SSR 2, suppose I reflectively know this much: I have a good
view of something on the hill that looks just like a sheep, on numerous
such occasions when I accosted the sheep-shaped thing, it was invariably
2013 The Authors
Pacific Philosophical Quarterly 2013 John Wiley & Sons Ltd & University of Southern California.

PACIFIC PHILOSOPHICAL QUARTERLY

a sheep, Im an expert at identifying sheep, and Im aware of nothing that

warrants doubting its one. In virtually all the nearby worlds ordered in
terms of this reflectively assessable knowledge, I see a sheep on the hill.
In sum, SSR 2 is neither reflectively nor veritically lucky; so it isnt
epistemically lucky. Both SSR 1 and SSR 2 exclude knowledge because
they are based on the same knowledge-nullifying mistake. Hence neither
Gettier case depends on epistemic luck to defeat knowledge.6

4.

Another unlucky Gettier case

My friend, Sally, takes me for a drive in her new Porsche, shows me the
bill of sale, and so on.7 Sally has always proven honest in the past, and Im
aware of no reason to disbelieve her. I conclude that she is presenting me
with what she says is her new Porsche because she owns one, and I
whimsically infer D: Sally is presenting me with what she says is her new
Porsche because she owns one, or Venusians have bribed her to deceive
me. (I routinely add the second disjunct to suitable propositions, a private
joke to which Im addicted.) In fact a Venusian research team has bribed
Sally to deceive me, and lent her the automobile. Suppose, too, that
Venusians alone want to bribe Sally, she doesnt play practical jokes
without a substantial bribe, shes broke (though I dont know it), and
nobody is about to give her a car.
Note that my belief that D tracks the truth. If D had been false, it would
have been because the Venusians didnt bribe Sally to deceive me. As
stipulated, no one is waiting in the wings to bribe her, and Sally, unbribed,
isnt going to come up with a Porsche. So if the Venusians dont bribe her,
shes not going to show me her new Porsche or even tell me she owns one.
What if D had been true? Note that the second disjunct is true in the close
possible non-actual worlds where D is true; hence I believe D in those
worlds, e.g. the Venusians lend Sally a different color or model Porsche.8
Further, D is true in the closest relevant worlds where I arrive at my belief
that D in the way I actually did, so the safety condition also is satisfied. So
my belief isnt veritically lucky.
Nor is it subject to reflective luck. After all, I know that Sally, who has
always proven honest in the past, has taken me for a drive in what she says
is her new Porsche, shown me what she says is the bill of sale (which looks
fine to me, an expert on such documents), and that Im aware of no reason
to disbelieve her. D is true in virtually all nearby possible worlds so
ordered. So my belief that D is not true due to reflective luck. In short, my
belief that D is justified by good reflectively assessable reasons.
Nonetheless its strongly counterintuitive to insist I know D. I inferred
D from the false disjunct and I have no warrant for the true one; indeed,
I attached it because I disbelieve it. My true belief fails to be knowledge for
2013 The Authors
Pacific Philosophical Quarterly 2013 John Wiley & Sons Ltd & University of Southern California.

UNLUCKY GETTIER CASES

standard Gettier reasons. Note that the example mimics the logical structure of the second of Edmund Gettiers original cases (Gettier, 1963).9
Here we have a second Gettier case where my justified true belief isnt
true due to epistemic luck. Why isnt it knowledge? On account of Sallys
deception, I mistake a situation where Sally doesnt own a Porsche for one
where she does. If I learned Id made it, I wouldnt even believe D.

5.

Two questions

Unlucky Gettier cases motivate two related questions. First, if epistemic

luck isnt distinctive of Gettier cases, what is? Second, what do Gettier
cases reveal about knowledge? I offer one answer to both. Necessarily, if
my true belief that b is knowledge, then, for every knowledge nullifying
mistake m that can readily be made in my general circumstances by a
normally-able human observer, my good reflectively assessable reasons for
believing b preclude the beliefs being based on m.10
To take an example from Alvin Goldman (Goldman, 1976; originally
due to Carl Ginet), suppose Im an ordinary fellow unwittingly looking at
the one real barn in an area peppered with papier-mch barn-facades.
The above condition is unsatisfied, which is why my justified true belief
that I see a barn isnt knowledge. On the other hand, the condition is
satisfied if Im an expert on papier-mch who can immediately spot it
visually even at a distance. My visual experience of the barn is part of the
reflectively assessable reasons why I believe theres a barn before me, and
it precludes my beliefs being based on mistaking a papier-mch facade
for a barn even though I never suspect that such a mistake might readily
be made in the circumstances in which I judge.11
Note, too, that the constraint on knowledge is vacuously satisfied when
no relevant knowledge nullifying mistake can readily be made in the
general circumstances in which a normally-able human observer judges;
for instance, the barn I see is in ordinary-barn county. So the constraint
is typically satisfied. The motivating mistake must be one that can be
readily made in the circumstances in which I judge, whether or not Im
aware of it.
In sum, Gettier cases, both lucky and unlucky, consist of true beliefs
whose justification precludes reflective luck but not such mistakes. This,
not epistemic luck, is what is most distinctive of them. What do they
reveal about knowledge? The constraint and its force. Knowledge that b,
if it is justified true belief, is such that, for every knowledge-nullifying
mistake m that can readily be made in Ss general circumstances, Ss
reflectively assessable reasons for believing b preclude his beliefs being
based on m.12
2013 The Authors
Pacific Philosophical Quarterly 2013 John Wiley & Sons Ltd & University of Southern California.

PACIFIC PHILOSOPHICAL QUARTERLY

6.

Conclusion

B. J. C. Madison expresses the prevailing conviction when he writes that

Gettier cases share a common structure:
Notably, luck is always present in a Gettier case. There is always some odd way that the
justified belief is made true, in that the belief would have been false, but for some strange twist
of good luck (Madison, 2011, p. 48).

Ive given what I submit are persuasive examples of unlucky Gettier

cases. Its easy enough to generate more. I conclude that the Gettier
problem has been underestimated and misunderstood. For instance, even
attaching a broad anti-luck codicil to the tripartite account leaves the
problem intact. Considering unlucky Gettier cases may help move us
forward.13
Department of Philosophy
The University of New Orleans
NOTES
1

I would ultimately deny that the adherence conditions satisfaction is necessary to

preclude veritic luck; my claim, above, is that the conjunction of sensitivity and adherence is
sufficient to do so. I believe that sensitivity and safety (see below) are sufficient, too. As part
of a strong anti-luck constraint, however, I will assume here and in sections 1, 2, 3 and 4,
below, that adherence is necessary to preclude veritic luck. I thereby make it harder to find
the counterexamples I seek.
2
Roughly and intuitively, the difference between adherence and safety is this. Adherence:
If what I believe had been true, I would have believed it. My belief sticks to the truth. Safety:
If I had believed what I do, it would have been true. The truth sticks to my belief.
3
I focus on the very influential account of luck which I find most clear and persuasive.
However the article has a substantial thesis for those who doubt that some external epistemic
condition ensures the agents true belief cannot be acquired in a veritically lucky fashion. Its
this: Either Gettier cases do not depend on veritic luck or external epistemic conditions will
not avoid it. Of course, those who insist that some external condition or other precludes
veritic luck can object that there might still be such a condition; my article doesnt prove
otherwise. If this is to have more force than hand waving, however, it is incumbent on them
to provide it.
4
Nozick maintains that, typically, S knows that p via a way of coming to believe p. So the
sensitivity and adherence conditions must be understood relative to a method. He writes: I
know there is a pair of scissors on my desk . . . now; but it is not accurate simply to say that
if there were a pair of scissors there, I would believe there was. For what if I werent looking,
or hadnt looked, or were elsewhere now?(p. 185). In my example, my method of coming to
believe that a sheep is on that hilltop is by looking at that hilltop.
5
The cognitive process neednt be inferential e.g. Im not reasoning from premisses to
conclusion when I believe a sheep is on the hill on the basis of taking a rock for a sheep. Also,
given overt inferential reasoning, even from premisses I know are true, there can still be an
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Pacific Philosophical Quarterly 2013 John Wiley & Sons Ltd & University of Southern California.

UNLUCKY GETTIER CASES

underlying cognitive process leading to my belief, one that involves a knowledge-nullifying

mistake. So, when I know that my colleague, Hanks, tells me he owns a Lincoln, and I
correctly infer that there exists a colleague who tells me this, from which I justifiably infer that
someone who is a colleague owns a Lincoln, if I learn that Hanks does not own one, I would
seriously doubt my conclusion (compare Feldman, 1974; also see next paragraph).
6
Im lucky Im in a county where my true belief is neither veritically lucky nor false. Does
this higher-order luck account for the Gettier intuition? Lets eliminate it. God (for his own
deep reasons) wants me to arrive at Gettier beliefs without forming veritically lucky beliefs.
He long ago introduced shy sheep and idolaters into the county; he now leads me to walk in
it. If it werent as it is, I wouldnt be there. If I werent going to be there, it wouldnt be as it
is. Since the falsehood that I see a sheep on the hill is my whole reason for believing one is
there, as the first belief plainly isnt knowledge, neither is the second.
7
This is a revised descendent of an example I deployed in Stone, 2000, specifically against
Nozicks theory of knowledge.
8
I believe D even in the more distant worlds where the first disjunct is true. In all these
cases, the relevant method by way of which I come to believe D is by observing Sally present
the car to me, hearing her tell me she owns it, and viewing the bill of sale.
9
As safe belief that tracks the truth and isnt reflectively lucky is insufficient for knowledge, the bullet-biting objection to SSR 2 that I do know a sheep is on the hill, since my true
belief is safe, tracks the truth, and isnt reflectively lucky, is invalid.
10
Arguably this can be viewed as a species of the indefeasibility account of knowledge (see
Lehrer and Paxson, 1969), but one that severely restricts the sorts of things which can count
as defeaters. Also, Im not offering an entire account of knowledge, but merely an additional condition. Of course, this constraint is to be read on the understanding that I have no
information such that m, were I to make it, would not be a knowledge-nullifying mistake in
my case (see end of Section 2, above).
11
Ss reflectively assessable reasons preclude his beliefs being based on m, when, if S
wanted to determine whether his belief was based on m, his reasons would enable him to tell
that it was not.
12
Jill reads an accurate newspaper-report of the presidents assassination; as its detailed
and the media have always been reliable, she justifiably believes hes dead (b). Meanwhile
elements in the government are widely broadcasting the lie that only a bodyguard was killed.
Jill would believe these reports, or anyway doubt b, but she happens not to see them (this is
a version of Harman, 1973). In my experience, intuitions are divided as to whether Jill knows
b (to the victor go the spoils, I submit). I say she knows b: as her belief is justified, that she
misses disinformation doesnt undercut her knowledge. Must I not say Jill knows b even
though she could easily have made a mistake? However her belief couldnt have been based
on mistakes she could easily have made; those would have led her to believe not-b. So the
condition on knowledge is satisfied.
13
My thanks for comments to Juan Comesaa, Joe Salerno, and to two anonymous
referees from this journal. I am substantially indebted to John Greco, who gave me detailed
comments on several earlier drafts.
REFERENCES
Feldman, R. (1974). An Alleged Defect in Gettier Counterexamples, Australasian Journal of
Philosophy 52, pp. 689.
Gettier, E. L. (1963). Is Justified True Belief Knowledge? Analysis 23, pp. 1213.
Goldman, A. (1976). Discrimination and Perceptual Knowledge, The Journal of Philosophy
73, pp. 771791.
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Harman. G. (1973). Thought. Princeton, NJ: Princeton University Press.

Hetherington, S. (2005). Gettier Problems, in J. Fieser and B. Dowden (eds), The Internet
Encyclopedia of Philosophy. Available online at: http://www.iep.utm.edu/gettier/
Lehrer, K. and Paxson, T. (1969). Knowledge: Undefeated Justified True Belief, The
Journal of Philosophy 66(8), pp. 22537.
Madison, B. J. C. (2011). Combating Anti Anti-Luck Epistemology, Australasian Journal of
Philosophy 89(1), pp. 4758.
Nozick, R. (1981). Philosophical Explanations. Cambridge, MA: The Belknap Press of
Harvard University Press.
Pritchard, D. (2005). Epistemic Luck. Oxford: Oxford University Press.
Stone, J. (2000). Skepticism as a Theory of Knowledge, Philosophy and Phenomenological
Research LX(3), pp. 527546.
Unger, P. (1968). An Analysis of Factual Knowledge, Journal of Philosophy 65(6), pp.
157170.

2013 The Authors

Pacific Philosophical Quarterly 2013 John Wiley & Sons Ltd & University of Southern California.