Rogue High Court Citation May Spark Legal Writing Changes

By Carrie Garrison (March 11, 2021, 4:03 PM EST) -- On Feb. 25, Justice Clarence Thomas, writing for a unanimous U.S. Supreme Court in Brownback v. King,[1] used the parenthetical "(cleaned up)" after a citation to denote the court's omission of quotations within quotations and the need for a quoting citation parenthetical, as dictated by Bluebook Rule 5.2.

This decision represents a rare and unique innovation in the field of legal writing and a win for appellate lawyer Jack Metzler, who first proposed the citation[2] in 2017 on #AppellateTwitter.

While seemingly mundane, the court's use of this citation format is significant, as it is the most notable change since the Supreme...

Stay ahead of the curve

In the legal profession, information is the key to success. You have to know what’s happening with clients, competitors, practice areas, and industries. Law360 provides the intelligence you need to remain an expert and beat the competition.

  • Access to case data within articles (numbers, filings, courts, nature of suit, and more.)
  • Access to attached documents such as briefs, petitions, complaints, decisions, motions, etc.
  • Create custom alerts for specific article and case topics and so much more!


Attached Documents

Related Sections

Law Firms


Government Agencies

Judge Analytics

Hello! I'm Law360's automated support bot.

How can I help you today?

For example, you can type:
  • I forgot my password
  • I took a free trial but didn't get a verification email
  • How do I sign up for a newsletter?
Ask a question!