More 'Cleaning Up' to do: 'Cleaned Up' in Federal Courts

By: Benjamin G. Shatz | Patrice Ruane
– Daily Journal

Manatt Appellate Partner Benjamin Shatz and Litigation Associate Patrice Ruane wrote a Daily Journal column expanding on how the “cleaned up” legal citation format is increasingly being adopted throughout the court system. 

Although the “cleaned up” citation in legal documentation is not currently an official rule in the Bluebook, the authors explained, this parenthetical has appeared in thousands of federal court opinions since being introduced in 2017. Federal judges were of the first to adopt this method and practitioners nationwide are joining in. Despite concerns, Shatz and Ruane found no instances of “cleaned up” being unethically used to blur meaning and they highlight the benefits of removing nested quotations. “These conclusions should serve to embolden those who wish to use an eminently sensible improvement to legal citation,” the authors wrote. “Momentum is swingingly heavily in favor of ‘cleaned up.’” 

Daily Journal subscribers can read the full article here

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