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Cleaning Up Quotations

Journal of Appellate Practice and Process, 2018, Forthcoming

26 Pages Posted: 22 Mar 2017 Last revised: 12 Sep 2017

Jack Metzler


Date Written: March 17, 2017


Lawyers use a lot of quotations in their writing. And judges are lawyers who are just as enamored with quotations in their writing as the rest of us. So it often turns out that the best quotation for a proposition is one in which a judge has quoted some other judge, and there's a good chance that judge was quoting yet another.The Bluebook dictates how to cite the original source of quoted material, how to indicate that the quotation contains a quotation, and how to show any alterations to the immediate source or the original source. But once the quotation contains a quotation, the Bluebook rules often mean that good quotes quickly acquire a significant amount of citation baggage that makes it difficult to use them without significantly distracting from the author's point or increasing the author's work for little substantive gain. The paper proposes that legal writers discard all that baggage and adopt a new parenthetical, "(cleaned up)," to tell readers that they have removed extraneous material for readability and guarantee that nothing removed was important.

Suggested Citation

Metzler, Jack, Cleaning Up Quotations (March 17, 2017). Journal of Appellate Practice and Process, 2018, Forthcoming. Available at SSRN: or

Theodore Metzler (Contact Author)

Independent ( email )

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