In an Austronesian-type voice system, a single argument is designated the "pivot" in each clause, with verbal morphology indicating the choice of pivot and corresponding changes in case marking and extraction possibilities. It has been suggested that ergativity plays a crucial role in Austronesian-type voice systems. In this paper, we argue that voice marking and case reflect separate but interacting systems, which can be dissociated from each other, based on the behavior of voice in Dinka (Nilotic; South Sudan) and Balinese (Austronesian; Indonesia). These languages exhibit familiar voice morphology, but can clearly be shown to not involve any ergativity. Instead, we propose that what unifies “voice” system behavior is a lack of structural licensing for the subject in Non-Subject Voices. We show that different voice systems solve this problem in different ways: Balinese licenses the subject under adjacency with the verb, whereas Dinka allows for last resort assignment of genitive case like in many Austronesian languages of the Philippines and of Taiwan.