Using “(cleaned up)” and Other New Parentheticals in Legal Citations

Noted appellate practitioner Jack Metzler last year proposed that we use the parenthetical “(cleaned up)” to indicate the omission of “messy quotation marks, ellipses, etc.” from a quoted authority. This idea has taken hold, appearing in over 100 judicial opinion. For Green Bag, Michael S. Kwun takes a look at new parentheticals.

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