‘Cleaned Up’ California: 7 Years On

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

Manatt Appellate Partner Benjamin Shatz and Litigation Associate Patrice Ruane wrote a Daily Journal column about the “cleaned up” method of citation in court filings and whether legal writers can use this unofficial style in their own documents. 

Currently, the official rules for legal citation formatting often require additional sets of punctuation that can create a cluttered look within documentations and court filings. In 2017, an attorney proposed a new citation parenthetical referred to as “cleaned up” with the goal of simplifying legal writing for an easier read by removing the added punctuation. While this rule still remains unofficial, Shatz and Ruane note that several California Court of Appeal Justices have incorporated “cleaned up” in their opinions. “What’s more, their writings give practitioners a road map to using ‘cleaned up’ in ways that make the best use of the signal and mitigate concerns about bad-faith usage that changes the meaning of the quoted material,” Shatz and Ruane wrote.  

Daily Journal subscribers can read the full article here.



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