I believe that the speed and breadth of the organic growth of the use of (cleaned up) reflects its readily apparent benefit—improving the readability of judicial opinions without sacrificing accuracy. That is why I use (cleaned up), including in the court’s opinion here. When quoting the governing precedent from our supreme court, it matters not that parts of the quotations were themselves quotations from prior supreme court cases. Adding in sets of internal quotations marks to set off those parts and extra parentheticals citing the cases from which those internal quotations came would serve little purpose. It is the words used by the supreme court in the case we quoted that govern. See Cleaning Up, at 152 (“A court’s decision is expressed in the words it uses in its opinion, not in the brackets and ellipses that might also appear in the opinion.”). And (cleaned up) alerts a reader that wishes to dive deeper that there is a quotation within the quotation that could be checked out by reading the cited case. So I generally see no need to clutter up our opinions with extra punctuation and citation baggage

Judge Langholz explains the origin of (cleaned up) and its rapid adoption, and then explains in plain terms why the parenthetical is useful. /2

LANGHOLZ, Judge (specially concurring). I continue on, beyond what is needed for the court to decide this case, to explain my persistent use of the legal-citation parenthetical (cleaned up) despite the contrary guidance of the latest edition of the Bluebook. See The Bluebook: A Uniform System of Citation R. B5.3, at 9 (Columbia L. Rev. Ass’n et al. eds., 22d ed. 2025) [hereinafter “Bluebook”]. Some may question—perhaps rightly—the importance of such a technicality. But I find the organic adoption of (cleaned up) to be a remarkable innovation in legal citation that improves the readability of judicial opinions and written advocacy. And (cleaned up) more accurately describes the practice that it notes than the Bluebook’s alternative: (citation modified). In short, (cleaned up) is worth saving. And I hope that the bench and the bar will not be bullied by the Bluebook into letting it die. The (cleaned up) Parenthetical. In 2017, an attorney proposed a new legal citation practice to address the problem of “excessive punctuation clutter” and “citation baggage” that accumulates when a legal writer quotes authority that itself

Thanks to @djsziff.bsky.social for alerting me to this important special concurrence from the Iowa Court of Appeals.
www.iowacourts.gov/courtcases/2...
I didn't realize at first that opinion goes beyond simply noting how (cleaned up) is superior to the Bluebook's (citation modified) version /1

Another good review, but this time with bonus state law (??!!) content. I appreciate in particular the succinct explanation of why (citation modified) is 👎🙄.

bsky.app/profile/djsz...

Another good review, but this time with bonus state law (??!!) content. I appreciate in particular the succinct explanation of why (citation modified) is 👎🙄.

bsky.app/profile/djsz...

My review was ⭐️⭐️⭐️⭐️⭐️ and it’s still one of my favorite things I’ve read in a law journal. BB22 makes me long for the apparently halcyon days of BB20.

Ooh! I haven’t tried it yet, but I did love the logic games. I hope Pips can recapture the magic of trying to seat eight people at a dinner party with different entrees and drinks!

I love love love this idea of fruit covered in LWI stickers. This is both hilarious and useful! Imagine the puns.

I got a little branded flashlight in a swag bag this summer and liked that. Sort of like mini umbrellas - can never have too many bc they evaporate somehow.

Question for the academic masses: What is conference swag you actually appreciate and use? Please limit your responses to affordable/reasonable things. (A free iPad would be cool, I guess... But come on.) Thanks!

I also use that bag! It’s a nice size and shape, although admittedly I am mostly putting in my car, which is roomier than Stephen’s bike saddle bags.

Chunks, because they are less messy. But kids seem to prefer wedges. Plus wedges are less work to make.

If it’s just me alone in my house the correct approach is to halve the watermelon and use a spoon.

Instead of “recommending” a substantive explanatory parenthetical when the cited authority isn’t otherwise clear to the reader, Bluebook 22 now “requires” the parenthetical in Whitepages Rule 1.5(a).

(No change to Bluepage/practitioner rules! But RIP journal article word counts…)

Fair point 😂😂

My aunt said that her friend raised one from a caterpillar and it grew to be 18 inches across!

Large yellow and brown moth covering an entire brick

This huge imperial moth was hanging out on the wall outside my office this morning. Those are standard sized bricks!

I love this 😂

Thank you for the shout out!

“I'm writing a first draft and reminding myself that I'm simply shovelling sand into a box so that later I can build castles.”
― Shannon Hale

#AcWri #GetYourManuscriptOut #AmWriting #WritingSky #AcademicSky

They should replace LAWN with a Junimo Hut to increase efficiency.

Call for Proposals for commentary and critique, an opportunity to engage with previously published works from the LC&R archive. We will accept and review proposals for commentary and critique on a rolling basis. Submit your proposal to lcr@alwd.org.

I feel seen. North Carolina is just big bites from here until November, with the occasional copperhead scare and a lot of sweating.

I’m also thinking of these signals in the practical usage context and how bringing over the law review complexity to briefs etc often isn’t helpful - different purposes and audiences, different use of sources etc.

And in a footnote! Agree as always with David.

The compare (and now contrast) signals seem like unnecessary complications bc you can write the same sentence without italicizing the signal and it still works. But maybe now invites a bit more explanation for the reader about the sources.

(reasoning obscured)

Late to all this, but why must we do this in the citations. Why? WHY? Just compare and contrast in regular sentences.

The sickest of burns, Jack!

Mistaking the cite for a multiplication problem?

Yikes

The number of times I have exclaimed “ooh!” in genuine surprised excitement upon getting an email from the person I watched send me that email 0.004 seconds earlier 🤦🏻‍♀️

I’m impressed you were able to save this for step 3!