 A second difference from Quine is also important. The crux of the Legal Realist position (at least for the majority of Realists) is that non-legal reasons (e.g., judgments of fairness, or consideration of commercial norms) explain the decisions. They, of course, explain the decisions by justifying them, though not necessarily by justifying a unique outcome (i.e., the non-legal reasons might themselves rationalize other decisions as well). Now clearly the descriptive story about the non-legal reasons is not going to be part of a non-mentalistic naturalization of the theory of adjudication: a causal explanation of decisions in terms of reasons (even non-legal reasons) does require taking the normative force of the reasons qua reasons seriously. The behaviorism of Quine or Underhill Moore is not in the offing here, but surely this is to be preferred: behaviorism failed as a foundation for empirical social science, while social-scientific theories employing mentalistic categories have flourished. Moreover, if the non-legal reasons are themselves indeterminate—i.e., if they do not justify a unique outcome—then any causal explanation of the decision will have to go beyond reasons to identify the psycho-social facts (e.g., about personality, class, gender, socialization, etc.) that cause the decision. Such a “naturalization” of the theory of adjudication might be insufficiently austere in its ontology for Quinean scruples, but it is still a recognizable attempt to subsume what judges do within a (social) scientific framework.