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Jack Metzler (cleaned up)

@scotusplaces.bsky.social

2.4K followers 180 following 2K posts

"Making statements with undertones of superior legal thinking."
Reporter of Decisions, Court of History.
Judicial review is a thing.™
Good behavior lol

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Jack Metzler (cleaned up)

@scotusplaces.bsky.social

your pic came out much better than mine ( there's a fox in this pic I promise)

picture of an alley at night with no apparent fox

November 25, 2025 at 12:00 AM

Jack Metzler (cleaned up)

@scotusplaces.bsky.social

I mean it depends on several things. First, is Comey is a person? Second, is he being asked to answer for a capital or other infamous crime? Third, is an indictment that a grand jury never saw an indictment of a grand jury? Fourth, is this an armed forces case during war? Many variables here.

November 19, 2025 at 4:45 PM

Jack Metzler (cleaned up)

@scotusplaces.bsky.social

one of these things is not like the others

an Eisenhower dollar, a Susan B. Anthony dollar, a Sacagawea dollar, and a Jefferson dollar

November 18, 2025 at 10:51 PM

Jack Metzler (cleaned up)

@scotusplaces.bsky.social

how did the foreperson sign an indictment the grand jury never voted on? why did they do that???

November 17, 2025 at 7:15 PM

Jack Metzler (cleaned up)

@scotusplaces.bsky.social

Correction: at least online, all but one of the law reviews have mastheads that list who worked on the Bluebook🤔

Screenshot of Harvard Law Review website "Sorry, page not found" page, which was the result when the link for "BOARD OF EDITORS" was clicked.

October 31, 2025 at 6:45 PM

Jack Metzler (cleaned up)

@scotusplaces.bsky.social

I would be so embarrassed to be one of the Bluebook editors involved in the decision to change (cleaned up) to (citation modified). Even people who don't like (cleaned up) think (citation modified) is worse, and the reasons for the change are more embarrassing still.

From article The Bluebook: An Insider's Perspective, by M. Burke Craighead:
But there was a final complication. One journal refused to use “cleaned up” as the actual parenthetical language. Based on a sour interaction with Jack Metzler, that journal did not want to use a term he coined. They also did not want it to seem like individual lawyers could dictate the terminology of citations to The Bluebook. They were willing to move forward with a similar parenthetical, but only if we used a different term. Thus, the “citation modified” parenthetical—with an express disavowal of the “cleaned up” parenthetical—was born (p. 9, Rule B5.3).

October 31, 2025 at 6:19 PM

Jack Metzler (cleaned up)

@scotusplaces.bsky.social

Judge Langholz does take issue with modifying initial capitalization w/o brackets. Though I disagree, I see where he's coming from. I always thought capitalization would be the most controversial part of my proposal, but this is the first time someone has raised it. /4

One Caveat. Still, I have one substantive quibble with the scope of cleaning up authorized by the Bluebook and the rule proposed by Metzler. Both authorize the writer to modify the quote to change capitalizations without noting the change by using brackets in the quote. Compare Bluebook R. B5.3, at 9, with Cleaning Up, at 154. I think this goes too far. In my view, using (cleaned up) does not weaken the intellectual integrity of a judicial opinion because the quotation still accurately states the text used by the quoted court. But altering the capitalization deviates from this principle. The writer is introducing another change beyond the splicing and alterations of the quoted court. And while capitalization is minor, a

[PAGE BREAK]
reader still gets important information from the use of brackets to show that the writer is making such a change. For example, noting a change to capitalize the first quoted word used to start a sentence tells us that the writer is cutting off some initial part of the quoted sentence. And fundamentally, noting every change to a quotation—however minor—builds trust that the writer is accurately quoting the governing precedent.

For this reason, when I use (cleaned up), I still bracket any capitalization alterations that I make to the quoted text. This practice better balances the

October 31, 2025 at 5:05 PM

Jack Metzler (cleaned up)

@scotusplaces.bsky.social

He goes on to recount the Bluebook's adoption of "citation modified" (and the less-than-honorable reasons the editors chose different verbiage), and explains why that formulation is "a misnomer twice over." /3

Even setting all that aside, the Bluebook’s alternative name is inferior to
(cleaned up). The term “citation modified” is a misnomer twice over. First, a writer using the parenthetical is not doing anything to the “citation.” The citation comes in the clause or sentence after the quotation, telling the reader the quotation’s source. Take for example, the first use of (cleaned up) on page 3 of the court’s

[PAGE BREAK]

opinion here. The citation is: “State v. Luke, 4 N.W.3d 450, 456 (Iowa 2024).” And we modified nothing about the case name or other information in that citation. Even if the term is intended to refer to a modified citation inside the quotation rather the citation sentence, that too makes no sense because no citation is left in the quotation after cleaning up the clutter.

Second, the writer has not “modified” anything of substance. True, the
writer has omitted punctuation marks and internal citations to leave only the substantive words as used by the quoted source. But it would be misleading to say this is a modification of that quotation—the essence of cleaning up a quotation is accurately quoting the substance of the source. Any modifications made by the writer should still be noted. Yet a parenthetical noting that the writer had “modified” something suggests there could be any modification—even substantive—leaving the reader confused and wary.

October 31, 2025 at 4:57 PM

Jack Metzler (cleaned up)

@scotusplaces.bsky.social

Judge Langholz explains the origin of (cleaned up) and its rapid adoption, and then explains in plain terms why the parenthetical is useful. /2

I believe that the speed and breadth of the organic growth of the use of (cleaned up) reflects its readily apparent benefit—improving the readability of judicial opinions without sacrificing accuracy. That is why I use (cleaned up), including in the court’s opinion here. When quoting the governing precedent from our supreme court, it matters not that parts of the quotations were themselves quotations from prior supreme court cases. Adding in sets of internal quotations marks to set off those parts and extra parentheticals citing the cases from which those internal quotations came would serve little purpose. It is the words used by the supreme court in the case we quoted that govern. See Cleaning Up, at 152 (“A court’s decision is expressed in the words it uses in its opinion, not in the brackets and ellipses that might also appear in the opinion.”). And (cleaned up) alerts a reader that wishes to dive deeper that there is a quotation within the quotation that could be checked out by reading the cited case. So I generally see no need to clutter up our opinions with extra punctuation and citation baggage

October 31, 2025 at 4:48 PM

Jack Metzler (cleaned up)

@scotusplaces.bsky.social

Thanks to @djsziff.bsky.social for alerting me to this important special concurrence from the Iowa Court of Appeals.
www.iowacourts.gov/courtcases/2...
I didn't realize at first that opinion goes beyond simply noting how (cleaned up) is superior to the Bluebook's (citation modified) version /1

LANGHOLZ, Judge (specially concurring).
I continue on, beyond what is needed for the court to decide this case, to explain my persistent use of the legal-citation parenthetical (cleaned up) despite the contrary guidance of the latest edition of the Bluebook. See The Bluebook: A Uniform System of Citation R. B5.3, at 9 (Columbia L. Rev. Ass’n et al. eds., 22d ed. 2025) [hereinafter “Bluebook”]. Some may question—perhaps rightly—the importance of such a technicality. But I find the organic adoption of (cleaned up) to be a remarkable innovation in legal citation that improves the readability of judicial opinions and written advocacy. And (cleaned up) more accurately describes the practice that it notes than the Bluebook’s alternative: (citation modified). In short, (cleaned up) is worth saving. And I hope that the bench and the bar will not be bullied by the Bluebook into letting it die.

The (cleaned up) Parenthetical. In 2017, an attorney proposed a new legal citation practice to address the problem of “excessive punctuation clutter” and “citation baggage” that accumulates when a legal writer quotes authority that itself

October 31, 2025 at 4:44 PM

Jack Metzler (cleaned up)

@scotusplaces.bsky.social

step one of planning my Smithsonian heist ✅

October 20, 2025 at 3:09 AM

Jack Metzler (cleaned up)

@scotusplaces.bsky.social

Brutal

Highlighted screenshot of ziff article excerpt:
Prepare Yourself for a New Signal: Contrast
Everyone is familiar with the basic citation signals: See, Cf., E.g., and so on. You might also be familiar with the Compare signal, which allows you to compare two authorities like this: Compare Case 1 (2023) (using the “cleaned up” parenthetical), with Case 2 (2024) [FOLLOWING TEXT HIGHLIGHTED] (asserting that the “cleaned up” parenthetical should never be used because of a personal grievance).

October 16, 2025 at 3:59 PM

Jack Metzler (cleaned up)

@scotusplaces.bsky.social

here's the reverse side (redacted)

Red and black card with name, bar id, and member since printed in white on the red side with the actual information on the black side, but the actual info is erased with magic eraser which makes it look like AI gobbledygook.

October 8, 2025 at 9:13 PM

Jack Metzler (cleaned up)

@scotusplaces.bsky.social

new DC Bar membership card just dropped

October 8, 2025 at 9:04 PM

Jack Metzler (cleaned up)

@scotusplaces.bsky.social

omg this has got to be the only thing in the world that my B.A. in studio art qualifies me for

screenshot from USPTO site on qualifications for design patent bar:
• Applicants must meet the following criteria to be admitted to take
the registration examination:
– Have a bachelor’s, master’s, or doctorate of philosophy
degree in any of the following areas (or its equivalent) from an
accredited college or university:
› Industrial design, product design, architecture, applied
arts, graphic design, fine/studio arts, or art teacher
education.

October 6, 2025 at 12:55 PM

Jack Metzler (cleaned up)

@scotusplaces.bsky.social

So if you happen to notice MS Word is repeatedly adding an extra paragraph mark at the end of every footnote (most likely after a new installation of Word), check if it's set to save as .odt for some god forsaken reason. That's the problem.

Screen capture of MS Word options:save tab, where the option Save files in this format: is set to OpenDocument Text (*.odt)". Change it to MS Word (*.docx) to avoid headaches.

October 1, 2025 at 3:52 PM

Jack Metzler (cleaned up)

@scotusplaces.bsky.social

Been waiting for an opportunity to post this
[translation: Beware cats jumping out]

Yellow warning sign with three silhouetted cats pouncing. Japanese text below says ネコ飛出し注意, which translates to Beware Cats Jumping Out

September 29, 2025 at 3:27 PM

Jack Metzler (cleaned up)

@scotusplaces.bsky.social

Speed Racer is the Wachowski's best film.

September 28, 2025 at 4:38 AM

Jack Metzler (cleaned up)

@scotusplaces.bsky.social

What do we think about this "writing tip"? It certainly makes the phases shorter, but does that necessarily make them better? Sometimes the longer phrase helps with the rhythm of a sentence. Sometimes it might be better to switch to a verb (the legislature intended). Is this generalization helpful?

Revise “of” phrases into possessives. For example:
• “the plain meaning of the statute” → “the statute’s plain meaning”
• “the intent of the legislature” → “the legislature’s intent”
• “the liability of the manufacturer” → “the manufacturer’s liability”

September 26, 2025 at 7:24 PM

Jack Metzler (cleaned up)

@scotusplaces.bsky.social

wow I this translate tool is better than I thought

screenshot of google translate:
Left side says language Microsoft - Detected
In the box below it says "Let's finish setting up your pc"
Right side translates to English. Translation is "Get ready for a bunch of bullshit offers"

September 26, 2025 at 2:29 AM

Jack Metzler (cleaned up)

@scotusplaces.bsky.social

OMG game changer! I just discovered the "citations" section of Westlaw's preferences. No more parallel citations to L.Ed and S.Ct.! You can also specify italics instead of underlining and add quotation marks before and after selected text you want to quote.