The word order in a phrase such as all John's friends , in which a universal quantifier is immediately followed by a genitive, is perfectly grammatical in Dutch but unacceptable in German. This article shows that there are three explanations for this difference between the two closely related languages. First, in German, the Saxon Genitive is a true case assigned in Spec, NP. In contrast, in Dutch and English, genitive case cannot be assigned in Spec, NP without a preposition. The Saxon Genitive in these languages is comparable to a possessive adjective that originates as the head of PossP and moves to D. Second, in a definite DP in a Germanic language, either D or Spec, DP must be occupied; if one of these positions is overtly occupied, and if genitive case has already been assigned, the movement of a genitive phrase to D or Spec, DP is unmotivated and causes ungrammaticality. Third, there is evidence that the -e inflection on the universal quantifier alle ‘all’ in German and Dutch has the characteristics of a determiner. *