In a legal citation, “(cleaned up)” means the writer has stripped non-substantive clutter out of a quotation — things like brackets around changed letters, ellipses marking omitted internal citations, nested quotation marks, and footnote reference numbers — without altering what the quoted text actually says. Appellate lawyer Jack Metzler proposed the parenthetical in 2017, and it has since appeared in thousands of federal court opinions, including a 2021 Supreme Court decision authored by Justice Clarence Thomas.
The Problem It Solves
Legal opinions constantly quote earlier opinions, which themselves quote still earlier opinions. Each layer drags along its own brackets, ellipses, quotation marks, footnote numbers, and internal citations. By the time a third or fourth court quotes the same passage, the result can be nearly unreadable. Traditional citation rules, particularly Bluebook Rule 5, require writers to preserve those artifacts so the reader can trace every alteration back through the chain of cases. The trade-off is readability.
The “(cleaned up)” parenthetical offers an escape. Strip out the clutter, present the substantive language in a single clean set of quotation marks, and signal to the reader that you have done so.
What a Cleaned-Up Citation Looks Like
Compare the same quotation under traditional Bluebook rules and with the parenthetical applied.
Traditional format: The First Circuit has held that “[p]ersecution normally involves ‘severe mistreatment at the hands of [a petitioner’s] own government,’ but it may also arise where ‘non-governmental actors . . . are in league with the government or are not controllable by the government.'” Ayala v. Holder, 683 F.3d 15, 17 (1st Cir. 2012) (second alteration and ellipsis in original) (quoting Silva v. Ashcroft, 394 F.3d 1, 7 (1st Cir. 2005)).
Cleaned-up format: The First Circuit has held that “persecution normally involves severe mistreatment at the hands of a petitioner’s own government, but it may also arise where non-governmental actors are in league with the government or are not controllable by the government.” Ayala v. Holder, 683 F.3d 15, 17 (1st Cir. 2012) (cleaned up).1Legal Writing Institute. Teaching Law Students Not to Make a Mess of (cleaned up)
The meaning is identical. The second version is just far easier to read. The writer cites only the case being directly quoted, not the earlier case the quoted court was itself quoting, and the single parenthetical replaces several explanatory parentheticals that would otherwise account for every bracket, ellipsis, and embedded citation.
Mechanically, you enclose the quoted language in one set of double quotation marks, remove the internal clutter, cite the source as if the words were original to that court, and add “(cleaned up)” at the end of the citation string.2North Carolina Bar Association. (Cleaned Up) Citations: A Bold New Option to Bluebook Rule 5 It goes at the very end, after any weight-of-authority signal or date parenthetical you need to keep.
What the Writer Can Change
Under Metzler’s original proposal, the parenthetical covers only alterations that affect appearance, not substance. A writer using it may:
- Remove brackets, ellipses, internal quotation marks, footnote reference numbers, and embedded citations within the quoted passage.1Legal Writing Institute. Teaching Law Students Not to Make a Mess of (cleaned up)
- Change a letter’s capitalization to fit the grammar of the surrounding sentence without putting the changed letter in brackets.2North Carolina Bar Association. (Cleaned Up) Citations: A Bold New Option to Bluebook Rule 5
- Make minor punctuation adjustments needed to integrate the quotation, so long as those changes do not affect meaning.
By using the parenthetical, the writer “affirmatively represents that the alterations were made solely to enhance readability and that the quotation otherwise faithfully reproduces the quoted text.”2North Carolina Bar Association. (Cleaned Up) Citations: A Bold New Option to Bluebook Rule 5 That representation is the whole point. You are staking your professional credibility on the claim that nothing substantive was altered.
What the Writer Cannot Change
The parenthetical is not a license to edit quotations freely. Any change that affects meaning, context, or emphasis falls outside the convention entirely.
- Omitting substantive words still requires ellipses. If the omission affects meaning, “(cleaned up)” is the wrong tool.
- Adding new language still requires brackets. Words that do not appear anywhere in the chain of quoted sources cannot be introduced silently.
- Shifts in reasoning or emphasis, even subtle ones, are off-limits. The convention covers formatting noise, not editorial choices.
- Major grammatical restructuring goes well beyond what the parenthetical is designed to cover.
If you have to think about whether an edit might shift the meaning, it probably does, and traditional alteration markers are the right call.
Where It Stands With the Bluebook and ALWD
The two major citation manuals in American legal writing have taken different approaches, and neither has fully embraced the convention.
The Bluebook’s 21st edition, published in 2020, said nothing about “(cleaned up)” at all. The 22nd edition appears to address it more directly but restrictively. One law library’s guide to the 22nd edition’s changes lists the parenthetical under alterations that are “NOT OK,” suggesting the newest Bluebook does not endorse the practice.
The ALWD Guide to Legal Citation, in its 7th edition published in 2021, acknowledged the convention without endorsing it. It advised law students to check with professors, and practitioners to check with supervisors and judges, before using it, noting that the parenthetical “is far from standard practice.”1Legal Writing Institute. Teaching Law Students Not to Make a Mess of (cleaned up)
How Courts Actually Treat It
The gap between the manuals and judicial practice is wide. The parenthetical has appeared in thousands of federal court opinions since 2017, with judges across multiple circuits using it regularly. The most prominent endorsement came in February 2021, when Justice Clarence Thomas used “(cleaned up)” in the Supreme Court’s opinion in Brownback v. King. A 2024 study by professors Shatz and Ruane found no instances of the parenthetical being used unethically to distort meaning, which has helped quiet earlier concerns about potential misuse.3Manatt, Phelps & Phillips, LLP. More Cleaning Up to Do: Cleaned Up in Federal Courts
State courts have been slower to weigh in formally. No state supreme court appears to have issued an order explicitly adopting or prohibiting the parenthetical, though individual state court judges do use it. Adoption has been organic and bottom-up: lawyers started using it, judges started using it, and formal rules have been playing catch-up.
When to Be Careful
Not every judge is a fan. The most notable judicial criticism came from Judge Britt C. Grant of the Eleventh Circuit, who wrote in Callahan v. United Network for Organ Sharing (2021) that “[a] (cleaned up) parenthetical has limited utility at most,” adding that “whatever utility that innovation may have will vanish entirely if it is used to obscure relevant information.”4Georgetown University Law Center. Untangling Unreliable Citations
A few situations call for extra care. When the source of the original language matters to your argument, stripping the citation chain may actually weaken your point. If the Supreme Court said something and a circuit court quoted it, your reader probably wants to know that. When brackets in the original reflect a substantive change made by an earlier court, removing those brackets could mask a meaningful alteration.
If you are writing for a court or judge whose preferences you do not know, the safest approach is still to follow traditional Bluebook rules for quotation alterations. The convention saves the reader effort, but only when the reader trusts it. In a filing where credibility matters most, that trust is not worth gambling on a formatting shortcut.