Lexical Case phenomena in German
Like Russian, German also exhibits lexical Case marking on the objects of verbs. Though the vast majority of the transitive verbs in the German lexicon take NP objects with accusative Case marking in active clauses, there also exists a set of verbs taking NP objects with dative Case marking. This contrast is illustrated in (1).
(1)

In (1a) the NP object of the verb beobachten “observe” occurs in the configurational accusative Case (hence den Spion), whereas in (17b) helfen ‘help’ selects a dative Case object (hence dem Spion).
German passive constructions exhibit an asymmetry in the behavior of configurational and lexical Case. A configurationally Case-marked object (that is, in the accusative) in an active construction occurs as a nominative in the subject position of a corresponding passive construction—as in English and Russian. In contrast, a lexically Case-marked object in an active construction remains in object position with the same lexical Case in the corresponding passive construction, as illustrated in (2b) as compared to (2a).
(2)

In the two passive constructions, the D-Structure object of beobachten occurs with nominative Case marking, in contrast to the D-Structure object of helfen, which retains its dative Case marking in the passive, as required by the PLS. The grammaticality of daß dem Spion geholfen wurde demonstrates that German differs from Russian in that the selection of lexical Case seems to be sufficient to license the occurrence of Case in a position that is not licensed for configurational Case.
Given that German does not have lexically Case-marked subjects, it should be expected that a lexically Case-marked object will not occur in subject position at S Structure. The motivation for this assumption will become clear in the discussion of Icelandic that follows. For German, then, Burzio’s generalization does not extend to lexical Case phenomena, though it remains valid for configurational Case phenomena.