Did John Marshall Harlan II Misuse the Word 'Suppletive'?

20 Green Bag 2d 239

13 Pages Posted: 24 May 2017

Date Written: May 23, 2017


In a 1980 interview, Henry Putzel, Jr., the 13th Reporter of Decisions for the Supreme Court of the United States, related a story in which Justice John Marshall Harlan is portrayed as insisting on using "suppletive" -- a word with an inapt if not nonsense definition -- in his concurring opinion in Labine v. United States, 401 U.S. 532, 540 (1971), over the Reporter's objection. The article pits Harlan against Putzel in three rounds of heavyweight semantic competition. The winner might surprise you.

Keywords: Supreme Court, Reporter of Decisions, Harlan, Putzel, suppletive, dictionaries, Legal Process

Suggested Citation

Metzler, Theodore, Did John Marshall Harlan II Misuse the Word 'Suppletive'? (May 23, 2017). 20 Green Bag 2d 239, Available at SSRN: https://ssrn.com/abstract=2972642

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