The Bluebook's "cleaned up"
One of the most notable changes in the new edition is the addition of “(citation modified)”—The Bluebook’s version of “(cleaned up).”
After much anticipation, the twenty-second edition of The Bluebook is here! How are we feeling about it?
One of the most notable changes in the new edition is the addition of “(citation modified)”—The Bluebook’s version of “(cleaned up).” Rule B5.3 says:
When a quotation includes material quoted from another source, the quotation may, for clarity, be stripped of internal quotation marks, brackets, ellipses, internal citations, and footnote reference numbers; the original sources of quotations within the quotation need not be cited parenthetically; and capitalization may be changed without brackets. Indicate these changes parenthetically with “(citation modified).” Other than the changes specified, the text of the quotation after modification should match the text used in the source cited. If the quotation is altered further, indicate the changes or omissions according to rules 5.3 and 5.3.
It also includes a Tip to not use “(cleaned up)”:
A few notes about this Rule
This Rule is specific about what it allows to be included in the "citation modified" grouping. If you make changes outside of the enumerated changes, you should follow Rules 5.2 and 5.3, as directed.
This Rule is in the Bluepages, which means it does not apply to law review journal citations.
Jack's Take
Jack Metzler initial created “(cleaned up)” by suggesting it on Twitter. It then took off when Justice Thomas used it in an opinion. Jack weighed in on this change and suggested that "(cleaned up)" remains the better option:
I hope you will advise people to keep using (cleaned up) . . . because "citation modified" is inaccurate (you don't modify the citation itself) . . . .
What do you think about the change?
A question about this Rule
Rule 1.5 does not include "(citation modified)" in the order of parentheticals explanation. That makes sense because it is not Whitepages-approved. So where do you put "(citation modified)" if you have other parentheticals since Rule B5.3 specifically contemplates other parentheticals?
Do we treat it as an explanatory parenthetical for purposes of Rule 1.5?
Have you used "(citation modified)"?
BBW Library
You can view all of my Bluebook Wednesday tips on the BBW library, hosted by the LegalEase Citations blog here.