Abstract
In order for us to have epistemic justification, Sinnott-Armstrong believes we do not have to be able to rule out all sceptical hypotheses. He suggests that it is sufficient if we have 'modestly justified beliefs', i.e., if our evidence rules out all non-sceptical alternatives. I argue that modest justification is not sufficient for epistemic justification. Either modest justification is independent of our ability to rule out sceptical hypotheses, but is not a kind of epistemic justification, or else modest justification is a kind of epistemic justification, but is not truly independent of our ability to rule out sceptical hypotheses.