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Guide to Legal Writing,
Appellate Practice

Jul. 2, 2024

More 'cleaning up' to do: 'cleaned up' in federal courts

The momentum is swinging heavily in favor of the 'cleaned up' legal citation format, making it a likely permanent addition to legal writing practices.

Benjamin G. Shatz

Partner, Manatt, Phelps & Phillips LLP

Appellate Law (Certified), Litigation


Benjamin is a certified specialist in appellate law who co-chairs the Appellate Practice Group at Manatt in the firm's Los Angeles office. Exceptionally Appealing appears the first Tuesday of the month.

Patrice Ruane

Associate, Manatt, Phelps & Phillips, LLP

Last month, we shared the story of "cleaned up" and explored how it has fared in California. Little did we know that this topic would ignite so many responses (mostly positive) about using the new signal. So this month we're sticking with that topic and digging a little deeper.

To recap, "cleaned up" is the citation parenthetical Jack Metzler proposed in a 2017 Twitter thread:

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