There have been many studies on the case and the theta theory of NP. We presented the case and theta theory from the Government- Binding framework to Minimalist Program in this paper. According to Stowell (1981), a clause does not receive a case even if it is assigned a theta role. If the argument is correct, there remains a problem how case features of T (nominative case) and V or v (accusative case) are checked. It is concluded that even if the distinction between the dependent and independent feature checking has been suggested for the case assigners, some constructions such as there and it expletive still cannot be checked their case features against the features of T and V (or v).