 Finally, like Goldman, Dretske associates justificationist accounts of knowledge with a tendency to over-intellectualize epistemic phenomena, to focus on “fancier” cases of knowing, cases which bring in (what he sees as) extraneous factors. The result is that the theorist is left having to reject some very clear cases of knowledge—in children, non-human animals, and unreflective adults—as not genuine knowledge at all (Dretske 1991). His own account of knowledge,