John Searle roundly rejects what he calls the Bad Argument: a long-standing equivocation in philosophy over the contents and the objects of perception. But, as Josh Armstrong points out, this insight is not unique to Searle. By the late 19th Century the equivocation had been observed by Franz Brentano and students of his, such as Alexius Meinong and Kazimierz Twardowski, and was highlighted too in the 20th century by G. E. M. Anscombe. What Armstrong does take to be a novel to Searle is his use of this observation to undermine some of the primary objections to a realist theory of perception. In fact, though, it had already been put to much the same use by Mary Shepherd in her 1827 book Essays on the Perception of an External Universe and Other Subjects Connected with the Doctrine of Causation. Shepherd not only argues that the equivocal use of the term “things we perceive” is a crucial flaw in Berkeley’s case for Idealism, but also goes on to use this in service of her own, largely realist, theory of perception.

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