We argue that English allows both rightward-descending VP shell structures and more traditional rightward-ascending VPs. The choice between these depends on case theory and economy. Case theory triggers VP shell formation whenever the verb is merged with a DP object after it has been merged with some other category. The reason is that VP shell formation allows verb and object to surface in adjacent positions, a prerequisite for case licensing in English. Economy has the effect that in all other circumstances, VP shell formation is blocked. Our argument is based on a range of intricate data, many of which involve the distribution of object-oriented floating quantifiers. We end with a discussion of the binding data that are often taken to support a uniformly descending structure—incorrectly, in our view.