|Abstract:||Default case appears when a DP cannot get case through normal syntactic mechanisms (SchÃ¼tze 2001). In an OT system, default case is best analyzed as an example of emergence of the unmarked. When case cannot be assigned, the least marked case is used. A constraint system is developed that includes markedness constraints for assigning structural case and faithfulness constraints for assigning nonstructural case (in partial agreement with Woolford 2001a). Default case is controlled by the ranking of constraints that penalize the appearance of certain cases -- the lowest ranked of such constraints correlates with the default case of the language. This is an argument against Woolford's (2001a) proposed universal ranking of these constraints. The constraint system developed here is used to analyze bare pronoun answers to questions (e.g. 'Who is going?', answer: 'Me.') in English (where default case is used) and German (where default case is not used).