Not much has changed in proper legal citation since I began law school other than the fact that the current edition of the Blue Book is much thicker and has larger pages than the relatively compact edition that I bought in 1980. Compare THE BLUEBOOK: A UNIFORM SYSTEM OF CITATION (Columbia Law Review Ass’n et al. eds., 20th ed. 2015), with A Uniform System of Citation (Columbia Law Review Ass’n et al. eds., 12h ed. 1976). However, a noteworthy event in the world of legal citation has occurred: A new parenthetical has been proposed and accepted almost immediately by the courts. See Jack Metzler, Cleaning Up Quotations, 18 J. APP. PRAC. AND PROC. 143 (2017).

In 2017, Jack Metzler posted online a draft law review article that advocated the use of a single parenthetical (cleaned up) to follow a citation where the author has dropped “superfluous material like brackets, ellipses, quotation marks, internal citations, and footnote references from their quotations.” Even before the article was published in final form, Maryland courts had begun to use the parenthetical (cleaned up), citing Metzler’s draft. See, e.g., Lamalfa v. Hearn, 457 Md. 350, 373 n.5, 178 A.3d 501, 514 n.5 (2018); Davis v. Frostburg Facility Operations, LLC, 457 Md. 275, 284 n.4, 177 A.3d 709, 714 n.4 (2018); Chassels v. Krepps, 235 Md. App. 1, 10 n.3; 174 A.3d 896, 901 n.3 (2017); Sang Ho Na v. Gillespie, 234 Md. App. 742, 752 n.2, 174 A.3d 742, 499 n.2 (2017). Several other state and federal courts have jumped on the bandwagon. See, e.g., United States v. Steward, 880 F.3d 983, 986 n.3 (8th Cir. 2018); Kolcraft Enterprises, Inc. v. Chicco USA, Inc., 2018 WL 3329706, at *5 n.10 (N.D. Ill. July 6, 2018); In re SB, 2018 WL 3471619 at *3 n.3 (Iowa Ct. App. 2018).

On August 7, 2018, Judge Dietz of the North Carolina Court of Appeals wrote in a concurring opinion:

The majority opinion uses the Latin phrase “purgandum” in a citation parenthetical to indicate that it removed unnecessary quotation marks, ellipses, brackets, or citations to improve the readability of the quoted text without altering its substance. Other courts and commentators suggest the phrase “cleaned up.” See, e.g., Jack Metzler, Cleaning Up Quotations, 18 J. App. Prac. & Process 143 (2017). Whatever notation is used, I support this practice and believe it is appropriate for counsel to use it in their briefs. So long as the substance of the quote is unchanged and the parenthetical informs the reader that there are non-substantive changes, this practice is consistent with the requirement in our rules that parties conform their filings “to the most recent edition of The Bluebook: A Uniform System of Citation.” N.C. R. App. P. App. B.

Jones v. Wells Fargo Co., 2018 WL 3733877, at *4 (N.C. Ct. App. Aug. 7, 2018) (Dietz, J., concurring).

The courts ready acceptance of Metzler’s proposal, while hardly revolutionary, is welcome news for those of us who write briefs and legal memoranda. I cannot wait to use it in my next brief.

If you have questions about legal memoranda and briefs, Astrachan Gunst Thomas, P.C., can help. Contact Mark Stichel at 410-783-3547 ( or Elizabeth Harlan at 410-783-3528 (