This paper examines case -marking deviations from the canonical pattern. We attempt to explain why and when case-marking deviations occur. Case-marking patterns are rarely consistent even within one language. In addition to the split case-marking in ergative languages, the deviant case-marking patterns in accusative languages are exhibited. In this paper, the so-called dative-subject constructions in Korean are considered as a deviant case-marking pattern. From a typological point of view, the Dat-Nom pattern in accusative languages and the Dat(Loc)-Abs pattern in ergative languages can be considered as a less transitive pattern being neither prototypical transitive nor intransitive. When stative predicates typically expressing the notions of mental and emotional experience, necessity, obligation, possession, and existence are involved, the less transitive Dat-Nom or Dat-Abs pattern is used in many languages. The canonical pattern and deviations from it are largely explained by the degree of transitivity which is determined in terms of semantic parameters.