become established as joined with integrated clauses, there are integrated clauses that do not necessarily express a distinguishing property of the referent. Such a (so-called) restrictive clause, actually a non-restrictive clause, is so completely integrated into the narrative and the intonation of the main sentence that it falsely appears to be restrictive. These examples of integrated relative clauses in that sense are not truly restrictive: "The father who had planned my life to the point of my unsought arrival in Brighton took it for granted that in the last three weeks of his legal guardianship I would still act as he directed." "He sounded like the clergyman [that] he was." (The Cambridge Grammar of the English Language) When the "restrictive" relative clause is removed from either of the above sentences, the antecedent ("the father" and "the clergyman") is not placed in question. In the first example, for instance, there is no suggestion that the narrator has two fathers because the relative clause does not express a distinguishing property of the subject. Instead, the relative clause is integrated but is not truly restrictive. That or which for non-human antecedents The distinction between the relative pronouns that and which to introduce restrictive relative clauses with non-human antecedents is a frequent point of dispute. For clarity, we can look at the case of non-human antecedents using the previous example: (1) The building company, which erects very fine houses, will make a large profit. (non-restrictive) (2) The building company that (or which) erects very fine houses will make a large profit. (restrictive) Of the two, it is consensus that only which is commonly used in non-restrictive clauses. Equivalently, the two cases would be applied where the statements are logically: (1) "which", non-restrictive: (The building company erects very fine houses) AND (The building company will make a large profit). (2) "that", restrictive: (The building company erects very fine houses) IMPLIES (The building company will make a large profit). The dispute concerns restrictive clauses. Both that and which are commonly used. However, for "polished" prose, many American style guides, such as the 16th edition of The Chicago Manual of Style, recommend generally avoiding which in restrictive relative clauses. This prescriptive 'rule' was proposed as early as 1851 by Goold Brown. It was championed in 1926 by H. W. Fowler, who said, "If writers would agree to regard that as the defining [restrictive] relative pronoun, and which