 Do approaches like Simple K-Reliabilism or the Simple Causal Theory fare any better than the JTB theory with respect to Gettier cases? Although some proponents have suggested they do—see e.g., Dretske 1985: 179; Plantinga 1993: 48—many of the standard counterexamples to the JTB theory appear to refute these views as well. Consider again the case of the barn facades. Henry sees a real barn, and that’s why he believes there is a barn nearby. This belief is formed by perceptual processes, which are by-and-large reliable: only rarely do they lead him into false beliefs. So it looks like the case meets the conditions of Simple K-Reliabilism just as much as it does those of the JTB theory. It is also a counterexample to the causal theory, since the real barn Henry perceives is causally responsible for his belief. There is reason to doubt, therefore, that shifting from justification to a condition like reliability will escape the Gettier  problem.[26]  Gettier cases seem to pose as much of a problem for K-reliabilism and causal theories as for the JTB account. Neither theory, unless amended with a clever “degettiering” clause, succeeds in stating sufficient conditions for  knowledge.[27]