The Death of Contra

6 Pages Posted: 27 Sep 2006

See all articles by James Ming Chen

James Ming Chen

Michigan State University - College of Law

Gil Grantmore

Jurisdynamics Network


Lemon isn't dead, but contra is. Once upon a time, truth was truth, and we had a way to signal what wasn't. Until 1996, the Bluebook directed lawyers to use contra when cited authority directly states the contrary of the proposition. The 16th edition of the Bluebook removed contra from the list of valid introductory signals.

The death of contra is the latest, surest sign of decadence and decline in American legal culture. It symbolizes the subtle subversion of law and legal scholarship. Where once clarity ruled, negation now lacks legal voice.

Poor contra! A legal culture that neither knows contra and nor respects its power is one in which the Supreme Court can spurn a condemned man's habeas petition because the Court had used cf. instead of see in another man's case. Lambrix v. Singletary, 520 U.S. 518 (1997).

O contra, now sent to Heaven, cursed by your fate. Accord, remain; you will be used, in courts as in the law reviews. Give us a way to signal lies, and forgive our omitted parentheticals, as we forgive those who force us to write parentheticals. And mock us not with citations, but deliver us from pedants. For in Hell there will be nothing but law, and the Bluebook will be meticulously observed.

Keywords: contra, citations, Bluebook, Harvard, Lambrix, accord, post-modernism, law reviews, legal writing, humor, satire

Suggested Citation

Chen, James Ming and Grantmore, Gil, The Death of Contra. Stanford Law Review, Vol. 52, p. 889, 2000 , Available at SSRN:

James Ming Chen (Contact Author)

Michigan State University - College of Law ( email )

318 Law College Building
East Lansing, MI 48824-1300
United States

Gil Grantmore

Jurisdynamics Network ( email )

c/o Jim Chen
648 North Shaw Lane
East Lansing, MI 48824
United States


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