For instance, to build the NP happy dogs from Cleveland in HPSG lexically would generate a lexical NP dogs incompatible with the constraints on modifiers like happy (which haveN MOD values) and further would prevent the added quantifier to outscope the modifiers.
a phrasal approach misses the broader generalization that these constructions are lexically triggered (by particular noun classes/inflection) and again heterogeneously spreads out language particular grammatical information between the lexicon and phrasal rules.