 The varieties of philosophical naturalism map on to a variety of naturalistic approaches in legal philosophy. The most radical version of M-naturalism, Replacement Naturalism, has been articulated and defended by Leiter (2001b) and arguably by the American Legal Realists (Llewellyn 1930; Moore and Callahan 1943; Leiter 1997). The less radical form of M-naturalism, Normative Naturalism, is exemplified in epistemology by Goldman (1978, 1986), but its implications for jurisprudence and law have been, to date, only partly developed (Allen &amp; Leiter 2001; Goldman 1999; Leiter 1998; Talbott &amp; Goldman 1998). S-naturalism features most prominently in the writings of the Scandinavian Legal Realists. S-naturalism has also played a role in motivating Legal Positivism in the Anglo-American legal-philosophical tradition. More recently, S-naturalism without normative skepticism has been defended by contemporary moral realists and natural law theorists like Brink (1988, 1989, 2001) and Moore (1985, 1992b).