By Rayce Miller.
The 22nd edition of The Bluebook: A Uniform System of Citation marks a victory for legal pragmatists, with Rule B5.3 creating the “citation modified” parenthetical. Before the 22nd edition, strict adherents to The Bluebook had to add multiple parentheticals to their citations whenever a quote was modified for readability. Citations ending in “emphasis added,” “footnote omitted,” “citation omitted,” and so on harmed readability and expanded the length of briefs. Now, The Bluebook offers a single parenthetical to perform the same function: “citation modified.” Hopefully leading to simpler citations and shorter briefs, this new rule to The Bluebook is the culmination of the Cleaned Up Movement, a movement started by Jack Meltzer in 2017.
The Cleaned Up Movement
In 2017, appellate attorney Jack Meltzer tweeted his frustrations about citing quotations in legal documents. Any modification of a quotation required a parenthetical explaining the change, even if the change did not affect the quote’s substance. After multiple minor changes to a quote, the parentheticals after the citation would multiply. Meltzer proposed a practical solution: “cleaned up.” This phrase would be used as a blanket parenthetical to replace the multiple parentheticals that were otherwise required. “Cleaned up,” then, would lead to shorter, more to-the-point citations. Later that year, he published an article advocating for this change in the Journal of Appellate Practice and Process.
Meltzer’s proposal sparked surprisingly vigorous debate in the legal community. Advocates of Meltzer’s approach valued its ability to simplify overly complicated and overly long citations, though some were hesitant to adopt what they described as a “bold new option.” Critics said that the “cleaned up” citation lacked transparency, hiding the exact changes made to the altered quote.
It seems the Arizona legal community was similarly divided. One article published by the Arizona Attorney Magazine heralded “cleaned up” as a “trend away from the formalities of The Bluebook, creating a more accessible structure for readers and writers alike.” An article by a Professor at the University of Arizona, however, was cautiously optimistic. Overall, the article supported “cleaned up” as a way to “enhance readability and improve flow” in legal writing. However, the article cautioned that the improper use of “cleaned up” could harm a writer’s credibility and violate legal ethics rules. For this reason, the article argues, law students and new attorneys should “be wary.”
Nonetheless, Meltzer’s new parenthetical spread. In February 2021, the Supreme Court of the United States used the parenthetical in a unanimous opinion. With the Supreme Court’s blessing, Arizona courts quickly followed suit. In April 2021, an Arizona appellate court used the citation tool. During that same month, the Arizona Supreme Court used “cleaned up” in an opinion by Justice Lopez. Even Arizona amicus briefs have used “cleaned up.”
The 22nd Edition of The Bluebook
Seemingly in response to the Cleaned Up Movement, The Bluebook adopted a rule that performs the same purpose: “citation modified.” Found in the new Rule B5.3, “citation modified” can be used instead of parentheticals such as “internal quotation marks omitted,” “footnote omitted,” “brackets omitted,” and so on.
“Cleaned up” critics can rest assured knowing that this rule is optional; if a practitioner prefers, they can continue to use the multiple, specific parentheticals originally required by The Bluebook. Additionally, this parenthetical can only be used when the changes were made solely to enhance readability. If the quote was changed in a substantive way beyond readability, “citation modified” is improper.
Why did the phrasing change from “cleaned up” to “citation modified?” One of the authors of the 22nd edition of The Bluebook had a “sour interaction” with Meltzer and did not want The Bluebook to use a term that Meltzer coined. In fact, the authors of The Bluebook expressly disavow the “cleaned up” parenthetical, sparking criticism from legal practitioners. Regardless, “citation modified” is The Bluebook-approved way to avoid numerous parentheticals.
Although “citation modified” is optional, this rule spread quickly in Arizona. The 22nd edition of The Bluebook was released in May 2025, and a panel of judges on the Arizona Court of Appeals almost immediately adopted the change, using the parenthetical in an opinion published on June 5th. The Arizona Supreme Court followed suit on August 20th.
For Arizona practitioners, the “citation modified” parenthetical has been quickly accepted into the norms of legal writing, representing a shift from legal formalism toward legal pragmatism. In a practice with ever-present page maximums, brevity is vital to an effective legal argument. Accepted by both the Arizona Supreme Court and Arizona appellate courts, practitioners should feel comfortable using “citation modified” as a way to shorten their citations and enhance their briefs.
Rayce Miller is a first-generation law student interested in becoming a trial lawyer for civil matters. Prior to law school, he studied Business Management at Lewis-Clark State College in North Idaho. He has experience competing in moot court competitions and is an active member in ASU’s trial team. He also serves as the President of the Food Law Society. Rayce has a passion for learning and discussing the law, with particular interest in Natural Law, Evidence, and Food Law.