Jack Metzler (cleaned up)

absolutely

I mean yeah I can see that but then you have to own it.

Correction: at least online, all but one of the law reviews have mastheads that list who worked on the Bluebook🤔

I still don't who I offended or how, but there are just four law reviews involved and they all have mastheads that say which of their editors was working on the Bluebook. It's a small set I am just saying.

If it were me, I would be loudly declaring that I was not the one who used my position to advance a personal grudge against someone without ever even confronting that person.

From article The Bluebook: An Insider's Perspective, by M. Burke Craighead: But there was a final complication. One journal refused to use “cleaned up” as the actual parenthetical language. Based on a sour interaction with Jack Metzler, that journal did not want to use a term he coined. They also did not want it to seem like individual lawyers could dictate the terminology of citations to The Bluebook. They were willing to move forward with a similar parenthetical, but only if we used a different term. Thus, the “citation modified” parenthetical—with an express disavowal of the “cleaned up” parenthetical—was born (p. 9, Rule B5.3).

I would be so embarrassed to be one of the Bluebook editors involved in the decision to change (cleaned up) to (citation modified). Even people who don't like (cleaned up) think (citation modified) is worse, and the reasons for the change are more embarrassing still.

A couple of notes:
1. The special concurrence was joined by Judge Badding.
2. Unlike (cleaned up), (citation modified) permits capitalization changes without brackets anywhere in the quotation, rather than just the first letter.
/x

In any case, the Judge's conclusion is sound:

"Bottom line, 'cleaned up' is a more accurate description of the quotation-decluttering practice that the Bluebook now authorizes. We should keep using it."
/5

One Caveat. Still, I have one substantive quibble with the scope of cleaning up authorized by the Bluebook and the rule proposed by Metzler. Both authorize the writer to modify the quote to change capitalizations without noting the change by using brackets in the quote. Compare Bluebook R. B5.3, at 9, with Cleaning Up, at 154. I think this goes too far. In my view, using (cleaned up) does not weaken the intellectual integrity of a judicial opinion because the quotation still accurately states the text used by the quoted court. But altering the capitalization deviates from this principle. The writer is introducing another change beyond the splicing and alterations of the quoted court. And while capitalization is minor, a [PAGE BREAK] reader still gets important information from the use of brackets to show that the writer is making such a change. For example, noting a change to capitalize the first quoted word used to start a sentence tells us that the writer is cutting off some initial part of the quoted sentence. And fundamentally, noting every change to a quotation—however minor—builds trust that the writer is accurately quoting the governing precedent. For this reason, when I use (cleaned up), I still bracket any capitalization alterations that I make to the quoted text. This practice better balances the

Judge Langholz does take issue with modifying initial capitalization w/o brackets. Though I disagree, I see where he's coming from. I always thought capitalization would be the most controversial part of my proposal, but this is the first time someone has raised it. /4

Even setting all that aside, the Bluebook’s alternative name is inferior to (cleaned up). The term “citation modified” is a misnomer twice over. First, a writer using the parenthetical is not doing anything to the “citation.” The citation comes in the clause or sentence after the quotation, telling the reader the quotation’s source. Take for example, the first use of (cleaned up) on page 3 of the court’s [PAGE BREAK] opinion here. The citation is: “State v. Luke, 4 N.W.3d 450, 456 (Iowa 2024).” And we modified nothing about the case name or other information in that citation. Even if the term is intended to refer to a modified citation inside the quotation rather the citation sentence, that too makes no sense because no citation is left in the quotation after cleaning up the clutter. Second, the writer has not “modified” anything of substance. True, the writer has omitted punctuation marks and internal citations to leave only the substantive words as used by the quoted source. But it would be misleading to say this is a modification of that quotation—the essence of cleaning up a quotation is accurately quoting the substance of the source. Any modifications made by the writer should still be noted. Yet a parenthetical noting that the writer had “modified” something suggests there could be any modification—even substantive—leaving the reader confused and wary.

He goes on to recount the Bluebook's adoption of "citation modified" (and the less-than-honorable reasons the editors chose different verbiage), and explains why that formulation is "a misnomer twice over." /3

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

u talking to the scientists or the candy?

failing to follow corporate formalities is so punk rock

Pierce the Veil has to be the hardest rock band named after a legal concept.

people protesting on the street are the only ones who ever want you to honk your horn

serious people will be like he should be defeated at the polls. not for this technicality. also, apparently States will be unable to keep him off of ballots. so what is anyone to do?

in 3 years we will be arguing about whether being constitutionally disqualified is disqualifying

@scotusplaces.bsky.social the lore grows.

It is worse than that Jennie, they didn't use (cleaned up) because somebody was mad at me personally, as the HLS BB editor explains in this article: papers.ssrn.com/sol3/papers....

I have no idea who it was or what I did, and nobody has ever owned up to being the person

Judge Langholz: judicial hero of the day.

çok güzel!

change a letter ruin a candy

Tootsie Poos
Spittles

Savage

are you on Turkiye?

Likewise if u are ever in DC!

WE HAD AN UPSTAIRS BOWLING BALL ROLLER TOO

Me too my fren. Lunch with Alice remains a highlight of my online-->rl experiences. Highly recommended.

Is anyone troubled, as an evidentiary matter, by the fact that email programs change the content of messages before they display them? For example, I often see [Ext] appended to a subject line, or a warning that the message came from outside the organization. How can we rely on altered messages?