Is the reliability of the process by which a belief is formed necessary for the belief’s justification? Are there not justified beliefs that would have been formed though false, by the method that did form them, even under normal conditions? Consider a person who mistakes certain bushes for trees, but is a reliable identifier of redwood trees. Observing a redwood, he believes justifiedly that there is a tree before him and this belief is justified, but he might have held this belief falsely by observing a bush.
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Leplin, J. (2009). Counterexamples. In: A Theory of Epistemic Justification. Philosophical Studies Series, vol 112. Springer, Dordrecht. https://doi.org/10.1007/978-1-4020-9567-2_10
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