 Quine’s argument for Replacement Naturalism, recall, moved in two steps. Step one was anti-foundationalism: no unique theory is justified on the basis of the evidential input. Step two was replacement: since no foundational story can be told about the relation between input (evidence) and output (theory), we should replace the normative program with a purely descriptive inquiry, e.g. the psychological study of what input causes what output. We can find analogues of both steps in the approach to the theory of adjudication offered by American Legal Realism.