 As is widely recognized, the Scandinavian Realists were ethical non-cognitivists. (Bjarup 1999, p. 775; Ross 1959, p. 313; Spaak 2009, pp. 42–44, 52–55, 64.) In principle, this would not require adopting expressivist or non-cognitivist accounts of legal statements, but as it happens Ross and Olivecrona did understand substantial parts of legal discourse on this model. To be sure, Ross analyzed statements about “valid law” as assertions of naturalistic fact, and thus cognitive. But, as discussed earlier, Ross thought some legal utterances were non-cognitive directives. This most obviously included legal rules themselves, as in the provisions of a statute. But Ross also thought jurists’ doctrinal writings were typically a blend of cognitive assertions of valid law and non-cognitive directives, the latter being in effect advice calculated to influence the behavior of the judiciary (1959, pp. 46–49). In advancing this idea, Ross was not merely making the banal point that doctrinal writing is frequently laced with transparently normative claims about how courts should decide cases. His point was subtler than this; telegraphically stated, Ross’ observation was that doctrinal writers sometimes do (and sometimes intend to) influence judges by making statements that could, on their face, equally be interpreted as straightforward predictive/descriptive claims. It turns out, therefore, that Ross had a rather nuanced understanding of the mix of cognitive (or representational/descriptive) and non-cognitive (or directive/prescriptive) elements in legal discourse.