Category Archives: Grammar

The Supreme Court Encounters Dueling Canons and Limiting Clauses

Consider this sentence:

Please bring home cheese, bread, and wine from Zupan’s.

What does this sentence mean? Is it a request to bring home cheese and bread from any store, and wine from Zupan’s? Or does it mean to purchase cheese, bread, and wine all from Zupan’s? I suspect most people would opt for the second option because it makes sense to get the cheese and bread at Zupan’s if you’re going there for wine.

How about this sentence:

She likes parrots, alligators, and puppies with soft fur.

What does this sentence mean? That she likes her parrots, alligators and puppies all to have soft fur? Or she likes parrots and alligators, and also puppies that have soft fur?  I suspect most people would choose the second option because of the biological unlikelihood of finding parrots and alligators with soft fur.

Thus, in the first sentence, the limiting clause at the end of the sentence applied to each item in the series. In the second sentence, the limiting clause applied to only the last item in the series.

These sentences illustrate the problem that arises when a series is followed by a limiting clause. The conundrum is whether the limiting clause applies to every item in the series, or only the last item.

In Lockhart v. United States, issued this week, the Supreme Court of the United States addressed this problem. The Court was asked to determine the meaning of a criminal statute providing an enhanced penalty for persons having a prior conviction for “aggravated sexual abuse, sexual abuse, or abusive sexual conduct involving a minor or ward * * * .”

The question was whether the limiting phrase “involving a minor or ward” applied to each of the preceding phrases (“aggravated sexual abuse, sexual abuse, or abusive sexual conduct”), or to only the last in the series (“abusive sexual conduct”).

Before reading further, decide for yourself. Done? Let’s move on.

The Court split 6-2 on the issue. Justice Sotomayor’s majority opinion held that the limiting clause applied to only the last item in the series. Justice Kagan’s dissenting opinion interpreted the statute to mean that the limiting clause applied to each of the three items in the series.

The majority relied on the “rule of the last antecedent.” That rule provides that where a list of terms or phrases is followed by a limiting clause, the limiting clause should be read as modifying only the noun or phrase that immediately precedes it. The dissent relied on a different (and conflicting) canon of statutory interpretation: the series-qualifier canon. That canon provides that where there is a parallel construction that involves all nouns or verbs in a series, a modifier at the end of the list normally applies to the entire series.

Both opinions make good points and a reasonable person could read the statute to have either meaning. The real lesson in Lockhart is that the careful writer should avoid the problem by making clear whether the limiting clause applies to each item in the series, or to only the last item.

For those interested in learning more, a copy of the decision can be downloaded here.

Lockhart v United States

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Collective nouns: singular or plural?

A collective noun is a word in singular form that names an aggregate of individuals or things. Some examples are “jury,” “group,” “faculty,” and “crowd.”

The problem is whether to treat a collective noun as a plural (“the jury are deliberating”) or as a singular (“the jury is deliberating”).

According to Bryan Garner, “there is little ‘right’ or ‘wrong’ on this subject.” But, generally, collective nouns take singular verbs, as in “the committee is meeting” and “the panel is in session.” But the most important point is this: be consistent. Decide on the style you’re going to use and stick with it.

That is all for now …


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We’ve got plenty to be thankful for (including hyphenated noun phrases)!

As we begin to enter the holiday season in earnest, many of us are reflecting on the things we are most thankful for.  I am thankful for my relatively sane family, my adorable dog, and, of course, hyphenated noun phrases.  What, you may ask, is a hyphenated noun phrase?  It is a phrase consisting of hyphenated words that create an adjective, followed by a noun.  For example: third-party defendant.  A hyphen combines the words “third” and “party” to form an adjective (“third-party”) that describes the noun, “defendant.”

These hyphenated noun phrases have a way of sticking with us.  In the same way that children add apostrophes in front of every single “s” they see once they learn about apostrophes, many of us overzealously hyphenate pairs of words that do not need hyphenation, presumably because we are used to seeing them hyphenated in a noun phrase context.  I have found that the most pervasive offender is “sign-up.”  The absolutely fine term “sign-up sheet” is such a familiar sight nowadays that I often find myself being incorrectly instructed to “sign-up” for something.

Let’s break this down: the two words, “sign” and “up,” are being combined with a hyphen so that they can form an adjective, “sign-up.”  That adjective then describes the noun, “sheet.”  Q: What kind of sheet is it?  A: It is a sign-up sheet.  However, were these two words to be used as a verb, there is no reason to hyphenate.  Therefore, I would sign up for an event on the sign-up sheet. Here are some other examples:

  • Be sure to eat every last bite of your mom’s well-done turkey.  She made sure it was well done because we all know what happens when it’s undercooked.  (“Well-done” describes “turkey.”)
  • Don’t bring up same-sex marriage at Thanksgiving dinner if discussing marriage between people of the same sex will lead to your auntie Ruth going off on a rant, thereby delaying dessert. (“Same-sex” describes “marriage.”)
  • Make sure your wine glass is more than half full during the holidays; a half-full glass is a recipe for disaster.  (“Half-full” describes “glass.”)
  • Your uncle Cleatus is a would-be lawyer; he would be a lawyer if he could properly hyphenate noun phrases, but alas, he cannot even spell his own name.  (“Would-be” describes “lawyer.”)  But he won his small claims case against that one landlord, so he could totally be a lawyer.  He bets it’s not even that hard.

One exception is that words ending in –ly are generally not hyphenated (see above use of “absolutely fine term”).  But thankfully, this general rule will serve you well:  when considering whether to hyphenate two words, ask yourself whether the words are forming an adjective to describe another word.   If yes, hyphenate.  If no, do not hyphenate.  Easy as pumpkin pie!

That is all for now …

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Possessing your “men,” “women,” and “children.”

On this 110th anniversary of the departure of Lewis & Clark’s “Corp of Discovery” from St. Louis on its journey to the Oregon Territory, we return to the endlessly fascinating subject of using the apostrophe-s to create the possessive form of nouns.  Upon receiving his mission from President Jefferson, Meriwether Lewis was reported to have remarked, “We will civilize these newly acquired lands by teaching the natives the correct usage of the apostrophe-s.”  Well, not really, but whatever.

The basic rules, which we reviewed earlier, are pretty easy.  The plural form of most nouns is created by simply adding “s,” e.g., native/natives, expedition/expeditions, river/rivers, boat/boats.  And the possessive form of these plural nouns is created by sticking an apostrophe after the “s.”

Simple enough.  But what about irregular plurals that don’t end in “s,” such as “men,” “women,” and “children”?  For example, is it the “men’s room” or the “mens’ room”?  The “women’s tournament” or the “womens’ tournament”?  The “children’s library” or the “childrens’ library”?

Fortunately, the rule for these irregular plurals is easy—simply add an apostrophe-s, e.g.,

  • The men’s room is to the right of the elevators.
  • The women’s tournament begins on Friday.
  • The children’s library is packed full of Nancy Drew books.

That is all for now …

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The Scribe’s Tip: Money – It’s a Gas!

As Pink Floyd once observed, “Money, it’s a gas/Grab that cash with both hands and make a stash.”  So today let’s talk about money, and more specifically, how to express dollars and cents in your writing.

First, when referring to dollars, use a dollar sign—don’t spell out “dollars”:

  • Correct:       $2 million
  • Incorrect:   $2 million dollars
  • Incorrect:   2 million dollars

And second, please leave cents out of your writing unless you are referring to mixed dollar and cents amounts:

  • Correct:      The judgment awarded $49,150.35 in damages and $945.32 in costs.
  • Correct:      The judgment awarded $49,150.35 in damages and $945.32 in costs.
  • Correct:      The judgment awarded $49,150 in damages and $945 in costs.
  • Incorrect:   The judgment awarded $49,150.00 in damages and $945.00 in costs.

Finally, at the risk of stirring up controversy, the Scribe must point out that Pink Floyd got one thing wrong.  Although they sang, “Money, so they say/Is the root of all evil today,” the actual saying—often attributed to ancient Greek poet Phocylides—is “The love of money is the mother of all evils.”  (Yes, the Scribe is aware that the saying also appears in 1 Timothy 6:10, but Phocylides said it first.)

That is all for now …

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Been an awful good girl!!

Today we discuss adjectives and adverbs.  Now that we are well into the Christmas season, I’m sure that you’ve all heard Eartha Kitt’s song “Santa Baby” dozens of times.  It begins, “Santa Baby, slip a sable under the tree, for me. Been an awful good girl, Santa baby, so hurry down the chimney tonight.”

If you’re not grammatically inclined, you may have mistaken the phrase “been an awful good girl” to mean “been an awfully good girl,” as in “a really good girl.”  But Eartha, being an awfully clever girl, instead uses two adjectives: “awful” and “good.”  This creates a bit of a play on words for those clever enough to catch it—has she been awful?  Has she been good?  Has she been both?

Simply put, the difference between adjectives and adverbs is this:  adjectives modify nouns, and adverbs modify verbs and adjectives.  This chart might help explain the difference a little better:

Form Word Example What is being modified? Question
Adjective Awful Been an awful good girl Girl (noun) What kind of girl has she been?  Awful and good.
Adverb Awfully Been an awfully good girl Good (adjective) How good has she been?  Awfully good.

Ask your kid what the difference between an adjective and an adverb is, and she might reply, “adverbs end in –ly!”  (Or she might reply, “I don’t understand the question.  Can I have a pillow pet for Christmas?”)  The rule we were taught in school—that adverbs end in –ly—is an incredibly confusing myth.  The rule works for most adjectives, e.g., nice – nicely; merry – merrily; drunken – drunkenly.  But some adjectives end in –ly, e.g., jolly, chilly, friendly.  And not all adverbs end in –ly, for example, the adjective “good” becomes the adverb “well.”

When in doubt as to how to form an adverb out of an adjective, it’s best to consult a dictionary, which will helpfully list the various forms of the word.  Be sure you’re aware of the distinction in meanings when using an adverb versus an adjective in your writing—you wouldn’t want to inadvertently imply to Santa that you haven’t been all that good this year, would you now?  We’ll leave that to Eartha.

That is all for now …

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Happy Thanksgiving. Oh, and observe pronoun/antecedent agreement!

The week we discuss pronoun/antecedent agreement.  As you recall from earlier tips, pronouns take the place of nouns.  Consider the following sentence:  “The Scribe went to the Oregon coast, where he enjoyed the Thanksgiving holiday.”  In that sentence, the pronoun “he” replaces the noun “The Scribe”—which, by the way, is the antecedent of “he.”

To avoid confusing the reader, a pronoun must agree with its antecedent in both number and gender.  For example, in the sentence “the boy met with his coach,” the pronoun (his) agrees in gender and number with its antecedent (boy).  It would clearly be incorrect to say “the boy met with her coach” or “the boy met with their coach.”  Got it?  Good!

This gets a bit more complicated when the antecedent noun is an indeterminate gender (e.g., player, attorney, judge).  Since it is generally considered sexist to use a male pronoun in such circumstances (“each player should meet with his coach”), some writers use either a plural pronoun (“each player should meet with their coach”) or a series of pronouns (“each player should meet with his or her coach”).

These are awkward solutions, and such gimmicks are just as likely to offend the reader as using sexist pronouns.  The better solution is to avoid the problem entirely by recasting the sentence to eliminate the pronoun, e.g., “players should meet with their coach.”

That is all for now … Happy Thanksgiving!

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