 The first point does not get developed by Davidson in any systematic way, though it has been explored by others interested in defending nonreductive monism from epiphenomenalist concerns. Some have focused on exploiting ceteris paribus covering laws for psychophysical causal relations, claiming that this allows mental properties to be sufficient for their effects, thus providing the needed type of explanatory role (McLaughlin 1989; Fodor 1989, 1991). Others have attempted to sidestep the issue of covering laws entirely by appealing directly to the truth of psychological and psychophysical counterfactuals in grounding the explanatory role of mental properties (LePore and Loewer 1987, 1989; Horgan 1989). Davidson himself instead focused on supervenience (although as we are about to see, the possibility of ceteris paribus laws enters into his account).