Yes, I’m a Lawyer

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Do you ever lie about your profession? Seriously. When someone asks what you do for a living, do you always say “I’m a lawyer”?

I do, of course. And I always sign my name with esquire. Even on checks. And I insist that everyone call me counselor.

Wife: Do you want any more salad, counselor?
Me: Nothing further at this time.

But there was a time when I didn’t want my membership in the bar to be the first thing a stranger learned about me. Often, I’d just as soon downplay my job—though I admit it took me a while to learn how. When I first came out of law school, I’d routinely do this:

Stranger: So, what do you do?
Me: I’m a lawyer. Or attorney. Strictly speaking, the distinction between the terms is disappearing at the present time. Moreover, there are the terms barrister, solicitor, and counselor, inter alia. Nonetheless, any and all of said terms can be utilized by laymen to refer to one who holds, possesses, or retains a juris doctorate.

That usually got a bad reaction.

But it wasn’t just my choice of words. I soon began to realize that as a lawyer, I wasn’t beloved by all. After a few years of law practice, I began to see that people had preconceived notions about lawyers and that telling someone I was a lawyer wasn’t always a good way to start off the relationship. So I fudged.

That was hard to do when I practiced law at a law firm. What could I say? But as a newly trained lawyer, of course, I was able to talk around the truth. That’s what they taught me in law school, right?

Stranger: So, what do you do?
Me: I’m a . . . well . . . what do you do?
Stranger: I’m a nurse. And you?
Me: I’m in finance. . . . I work with banks . . . lending . . . that sort of thing.

That was true, at least partly.

I didn’t say I represented the banks as a lawyer. I didn’t say I sued borrowers. I didn’t say I prepared for filing original petitions directed to defaulting debtors. That could come later, after the stranger had seen I was a decent person.

On the other hand, how decent was it to fudge on the truth in our first conversation? Still, I justified it. It was better than getting the typical reaction—usually something like this:

Stranger: An attorney, huh? My brother-in-law’s an attorney—a real jerk, too.

Or this:

Stranger: No offense, but I’ve had enough of attorneys for a lifetime. My ex’s attorney was a real jerk.

Yes, the “j” word came up a lot.

So when I got into academia as a legal-writing instructor, I took full advantage of the chance to obscure my profession. I started telling people I taught writing. Just “writing.” Not “legal writing.” That way I could pass myself off as an English teacher. Cool. Besides, try explaining legal writing, and you usually get a snide remark.

Me: I teach legal writing.
Stranger: So you’re the one who teaches them to write like that.

I still had awkward moments and lessons to learn. I found out that fudging about your profession didn’t always go smoothly. Once, I told someone I was a “writing instructor,” but she heard “riding instructor.”

She: Oh, it must be challenging working with those animals.
Me: Yeah . . . I guess . . . .
She: You always have to let them know who’s boss, right? Use the whip if you have to, I suppose?

But I’ve matured. I’ve learned to accept my profession—and to shrug off the critics. Now, in my 23rd year of teaching, I’ve abandoned the equivocating. I’m finally able to tell the truth. I’m proud to be a lawyer—a legal-writing instructor. So when asked, I now say what I feel, from my heart:

Me? I’m a legal-writing instructor. As a field, legal writing comprises drafting, advocacy, and expository analysis, though that three-pronged regime is subject to critique on the ground that it is not comprehensive. Furthermore . . . .

Semicolons: Not so Useless

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“How useless is the semicolon?”

A lawyer once asked me this question (emphasis in the original) and proceeded to offer three points in support. First, he said, a period can fulfill some of the semicolon’s functions, and second, a comma can fulfill the rest. Third, people abuse and confuse semicolons enough that we’d be better off without them. Well, I had to concede some of his points. But I was determined not to let “Mr. Useless,” as I’ll call him, get the better of me. No. I believe lawyers, as professional writers, have legitimate uses for the semicolon. Here are four.

1. Semicolons can separate independent clauses.
An independent clause has a subject and a verb and could be a sentence by itself. We can separate independent clauses with a period—as I had to concede to Mr. Useless.

We do not object to the amount of the fees. We ask that the amount not be disclosed to the public.

But a period between independent clauses says, “Full stop. New idea.” A semicolon between independent clauses says, “Pause; related idea.”

We do not object to the amount of the fees; we ask that the amount not be disclosed to the public.

So, Mr. Useless, the semicolon gives the professional writer another option—another tool for connecting ideas.

2. Semicolons separate phrases in a series when one or more of the phrases has internal commas.
This is a useful function more lawyers should apply. When you have three or more phrases in a series, you normally separate them with commas, which tells readers where each phrase ends. But when one of the phrases has commas within it, readers can get lost. In those cases, use the semicolon as a “super comma.” A basic example:

I have a sister in Princeton, New Jersey; a sister in Philadelphia, Pennsylvania; and a brother in Great Falls, Montana.

Contract drafters should get to know this semicolon. The modifiers and qualifications that appear in contract language sometimes result in sentences like this:

All other details as to format, title, time, and manner of production, of price, publication and advertisement, and the number of, and distribution of, editorial review and free copies will be left to the discretion of the Publisher.

Got that? It’s better with semicolons acting like super commas:

All other details as to format, title, time, and manner of production; price, publication, and advertisement; and the number and distribution of editorial-review and free copies will be left to the Publisher’s discretion.

And that, Mr. Useless, is something a period or comma can’t do.

3. Semicolons separate the items in a numbered list.
This isn’t so much a rule as a convention in legal writing. When you write a simple, textual list or series, you separate the items with commas—as I again had to concede to Mr. Useless. For example:

When arguing a case to the jury, remember to maintain regular eye contact, keep your argument short, and close with a challenge.

But in legal writing, once you number the items, semicolons become conventional, even though commas would also be correct:

When arguing a case to the jury, remember three things: (1) maintain regular eye contact; (2) keep your argument short; and (3) close with a challenge.

Semicolons are even more conventional when you tabulate the numbered list.

When arguing a case to the jury, remember three things:
(1) maintain regular eye contact;
(2) keep your argument short; and
(3) close with a challenge.

Why quarrel with convention, Mr. U?

4. Semicolons separate the authorities in a string citation.
Simple enough, and it’s one we already knew: Moran v. Adler, 570 S.W.2d 883, 888 (Tex. 1978); Heien v. Crabtree, 369 S.W.2d 28, 30 (Tex. 1963).

And you can’t use periods or commas for that, can you, Mr. Useless?


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What I wish I’d known about legal writing

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1. I wish I’d known that law was a writing profession.

I came to law school thinking law practice was an oral profession. I pictured myself in court, making an argument to the jury or to the judge. I pictured myself seated across the table from another lawyer, negotiating a deal. I pictured myself in my office, meeting with a client to give advice. Sure, lawyers do those things.

But mostly, they write.

Lawyers are professional writers. They get paid to produce quality written work that is subjected to serious scrutiny. I wish I’d known that.

2. I wish I’d known that becoming a good legal writer would take years.
I thought I was a good writer in college. I also thought the basic training I received in law school would enable me to write well in practice. I was wrong.

In Outliers by Malcolm Gladwell, he reports on a theory of developing expertise. The theory suggests that it takes 10,000 hours to develop expertise in a particular area. If the theory is right, it certainly applies to legal writing. So if you work 2000 hours per year, and 1000 of those hours are spent writing, becoming an expert legal writer would take you 10 years. That’s a long time.

But it’s not enough to just do the skill for 10,000 hours. You need to work at it—study, learn, and implement what you’ve learned. If you don’t study your craft—if you just write on auto-pilot—it’ll take you more than 10,000 hours. And if you write for fewer than 1000 hours per year, it’ll take you more than 10 years. It could take you 15 or 20. I wish I’d been aware of that long haul.

As an aside to the law students and young lawyers reading this, may I say that I sometimes hear from senior attorneys that law students and young lawyers are ineffective legal writers. This bothers me because it’s unrealistic to expect high-quality legal writing from novices who have spent far fewer than 10,000 hours practicing legal writing. I believe these often misguided complaints arise from two causes: First, some complainers are not expert legal writers themselves and are not in a position to fully judge expert legal writing. Second, some complainers have forgotten how ineffective and inexpert their own legal writing was when they were novices.

So hang in there, young lawyers.

3. I wish I’d known that time pressure would be a significant obstacle to good legal writing.
Law is a busy, demanding profession. Many lawyers feel compelled or are compelled to take on more work than would be ideal. The heavy workload impinges on effective legal writing.

Let’s take editing as an example. If your writing is less than expert, it might be because you don’t know how to edit. Or it might be because you know how to edit, but you’re too lazy to edit. But most often it’s probably because although you know how to edit and you’re hard-working, you don’t have time to edit. Editing is what makes weak writing good and good writing great. But in a busy law practice, careful editing often has to be sacrificed.

4. I wish I’d known about the best sources on good legal writing.
I didn’t own a book on legal writing until I quit practicing law and began teaching legal writing. How could that be? If I’d studied journalism, I would’ve known about and acquired books on writing style. Likewise if I had studied English composition. But I finished law school and entered a writing profession without a single source on legal writing in my library. Sure, I read The Elements of Style by Strunk and White. I read On Writing Well by William Zinsser. But I read no books on legal writing.

Given what was available when I graduated from law school in 1989, I wish I’d had these sources:

  • The Texas Law Review Manual on Usage and Style
  • A Dictionary of Modern Legal Usage, by Bryan A. Garner
  • How To Write Plain English, by Rudolf Flesch

Somebody should’ve given me one of these as a graduation gift.

Ultimately, I simply wish I had taken the skill of legal writing more seriously. You’re forewarned.

Manage your sentence length

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What’s a good average sentence length for legal writing? I once asked a group of lawyers at a CLE seminar that question. “Thirteen words,” one lawyer volunteered. “Seven,” said another. Wow.

Writing about legal matters with an average of seven words per sentence isn’t realistic, is it? That means for every sentence of ten words, you’ve got to write one of four words to bring the average to seven. That would be tough, but the instinct is right. Steven Stark, author of Writing to Win, says the more complex the material, the shorter the sentences should be.

So what’s a more realistic goal? The experts say between 20 and 25 words:

  • below 25—Richard Wydick in Plain English for Lawyers
  • about 22—Enquist & Oates in Just Writing: Grammar, Punctuation, and Style for the Legal Writer
  • about 20—Bryan Garner in Legal Writing in Plain English

How do you know your average sentence length? You can program Microsoft Word to tell you. In Word 2010 and 2013, go to File > Options > Proofing and look for “When correcting spelling and grammar in Word.” Now check the box for “Show readability statistics.”

You’ll also be required to check the box for “Check grammar with spelling.” If you dislike running a grammar-check every time you run a spell-check, go into the grammar settings and uncheck as many boxes as you like. Tell Word to stop checking for all those grammar items—it gets many of them wrong anyway.

Now when you finish a spell-check, you’ll see a display that includes the average sentence length. Of course, the tool isn’t perfect. If you have citations or headings in your text, Word will think those are sentences—short sentences—and your average sentence length will be artificially low. To work around this problem, select a paragraph or group of paragraphs without headings or citations and then run the spell-check; do it three times in different places. This will give you a sense of your average sentence length.

If your average sentence length is in the 30s, or even the high 20s, you’re taxing your readers. Do a thorough edit for concision and efficiency. If your average sentence length is in the teens, well done. You’re pleasing your readers. And remember, average sentence length doesn’t mean uniform sentence length. You should vary your sentence length. Write some short sentences and some longer ones.

But how long is too long? We lawyers have a reputation for long sentences. It’s probably not all our fault. After all, the subject matter of most legal writing lends itself to qualifications, modifiers, asides, and lists—so we might be forgiven. Yet I’m sure we can do better. Here’s a suggestion: Decide on a maximum sentence length and promise yourself you’ll cut any sentence that goes above your maximum. For example, mine is 45. I’ve decided that when a single sentence I’ve written exceeds 45 words, it’s an automatic edit.

Of course, some gifted writers can create long sentences that are pleasant to read; they usually use long but perfectly parallel phrases in a series. Or they use lots of semicolons. It can work in literature. But for most of us doing legal writing, long sentences are hard to read and hard to follow. So avoid over-long sentences.

In managing sentence length and avoiding over-long sentences, it’s not practical to count words while you type. Instead, manage sentence length on the edit. As you read your writing, keep an eye out for any sentence that fills three or more lines of text or any sentence that just makes you tired. Use your cursor to select that sentence, and Word will tell you the word count at the bottom left of your screen. For me, if it’s more than 45, it’s an automatic edit.

So that’s the advice. For readable writing that doesn’t tax your readers, vary your sentence length, seek an average in the low twenties, and cut any sentence of 45 words or more.


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Blog URL change

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The URL for this blog is now

The compound-modifier hyphen connects and clarifies

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Take advantage of our new customer discount. This means a new discount for customers, but I bet the writer meant a discount for new customers. We’re selling a little used car. This means the car is small, but I bet the writer meant the car had been used only a little. He has a family law practice. This means he practices with a relative, but I bet the writer meant he takes divorce cases.

What causes confusion in these examples is the absence of a hyphen. The rule—and yes, it’s a rule of written English, although some of us never learned it—requires a hyphen between words that jointly modify a noun. The Chicago Manual of Style § 7.81 (16th ed. 2010). These jointly modifying words are called “compound modifiers” or “phrasal adjectives.”

Careful writers hyphenate compound modifiers: Take advantage of our new-customer discount. We’re selling a little-used car. He has a family-law practice. The hyphen clarifies meaning, instantly telling the reader that the words modify the noun jointly, not independently. When the modifying phrase follows the noun, you need no hyphen: We offer a discount to a new customer. The car we’re selling is little used. His practice is in family law. You also need no hyphen for proper nouns (United States treaties), foreign phrases (prima facie case), and adverbs ending in -ly (highly skilled writer). You do need a hyphen for well phrases, like well-pleaded complaint, well-known jurist, and well-rounded person.

Some legal writers doubt the rule and say they don’t see compound-modifier hyphens in other writing. But the truth is they’re everywhere. We don’t notice them because they’re doing their job—smoothing out our reading and eliminating miscues. For the skeptical, I offer a sampling of hyphenated modifiers from a single edition of my local newspaper, the Austin American-Statesman. I recorded the first ten I saw:

single-family home
five-day period
technology-based processing system
city-owned street
since-discredited promise
60-vote majority
two-thirds requirement
far-reaching change
board-appointed reviewer
call-center jobs

If you look for them, you’ll find compound-modifier hyphens in any well-edited publication.

You can use several hyphens if the modifying phrase has several words. So all the following are correct: all-or-nothing strategy, on-the-spot investigation, two-year-old plan. But don’t get carried away with long, hyphenated modifying phrases. This might be okay: a sweep-it-under-the-rug approach, but this is too much: a let-the-jury-struggle-with-it-and-figure-it-out attitude.

You can also use a “suspended hyphen” if you don’t want to repeat the second part of two similar compound modifiers. So instead of right-brain and left-brain functions, you can do this: right- and left-brain functions, or 15- and 30-year mortgages.

In applying these hyphen rules, legal writers sometimes encounter a problem. In law we have many familiar expressions and phrases that technically require hyphens but that will not confuse if left unhyphenated. For example, all these would take hyphens: summary-judgment motion, good-faith effort, reasonable-person standard. But hyphenating them can seem pointless and, given that some readers don’t know the rule for compound-modifier hyphens, adding a hyphen might cause more confusion than it saves.

So you have a choice.

You can apply the hyphenate-your-compound-modifiers rule at all times, uniformly, even to familiar phrases. That way, you don’t have to stop and think about whether you’re causing confusion. You just follow the rule: I always hyphenate compound modifiers, and this is a compound modifier, so I’ll hyphenate. Bryan Garner, in Garner’s Modern American Usage, supports this “flat rule.”

Or you can apply the hyphenation rule when confusion might result, but not to familiar legal phrases. So you’d hyphenate high-performing employee and public-agency exception but not common law doctrine, third party beneficiary, or summary judgment motion. Of course, with the case-by-case approach you have to gauge your audience’s knowledge and differentiate general audiences from specialized ones. Thus, you’d probably need to hyphenate differently for a labor lawyer and for a generalist judge and maybe even for the judge’s clerk. As you can see, you avoid wrestling with tough calls if you apply the flat rule.

Whether you apply the flat rule or a case-by-case standard, put “hyphenate compound modifiers” or “hyphenate phrasal adjectives” on your editing checklist.


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The biggest impediment

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The biggest impediment to better legal writing isn’t the lack of quality instruction in law school.

It’s law practice.

Deadlines. Time limits. Conventions. Fear. Supervisor expectations. Local rules. Forms and templates. Money. Inertia. Complacency.

All these prevent lawyers from taking the appropriate time to polish their writing. For example, even if a lawyer has four weeks to write a brief, that’s not enough because the same lawyer has three other briefs, four memos, and eight letters to write at the same time, not to mention the 150 e-mail messages to read and respond to.

Revising, editing, and rewriting are what make mediocre writing good and good writing great, but lawyers don’t have enough time for them.

David Mellinkoff captured the nature of the busy law practice and its effects on legal writing:

Sometimes urgency forces precedence over everything else. Get it done. Get something out. We’ve got to file. This is a “rush.” The writer is under pressure to take shortcuts. This has become the normal environment of most legal writing, and is one of the principal reasons why so much of it is so bad.

David Mellinkoff, Legal Writing: Sense and Nonsense 116 (1982).

The unfortunate fact is that this kind of rushed approach often gets the job done—it’s often good enough or has to be. One reason it gets by is that many of us have been writing this way—under a deadline and without sufficient time devoted to polishing—since college:

Many young lawyers seem to have survived writing assignments in college and law school (with the exception of law-review writing) by turning in what were basically first drafts, lightly edited to fix glaring errors. They are unprepared to regard editing as a serious, laborious activity.

Stephen V. Armstrong & Timothy P. Terrell, Thinking Like a Writer: A Lawyer’s Guide to Effective Writing and Editing 298 (2003).

And so practicing lawyers continue to churn out mediocre or poor writing; the exigencies of modern life and law practice almost require it.

True writing classes are rare

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High-school classes that teach writing are rare. College classes that teach writing are rare. Graduate-school classes that teach writing are rare. In fact, for most of my first-year law students, the required legal-writing course is the first class they’ve ever taken that is actually and seriously about writing.

I can’t prove my assertions, but I offer three anecdotes.

1. Pre-AP English isn’t about writing.
I know a 10-grader taking Pre-AP English. The course focuses on literature, not writing. The course covers a dozen books and plays, and the students learn about mythology (The Odyssey, The Iliad), Shakespeare (Julius Caesar, Romeo & Juliet), religion (The Inferno), war (All Quiet on the Western Front), and more. They read and annotate these works, do group projects about them, and take tests on them.

What they don’t do much is write about them.

Yes, they usually write an essay as part of the test on each work, but that’s a timed, in-class writing project. Better than nothing, but not terribly practical. It’s really more about what they know than how well they can write. And besides, I’m convinced that high-school and college essays and the grading of high-school and college essays foster a formal, fancy, show-off type of writing, the kind everyone claims to hate but that many academics do and reward.

What’s more, for two of the works, the teacher had students prepare an essay outline and turn that in as the writing project. Not much writing practice there.

(I’m not complaining. I’m describing. Do you want to grade 100 10th-grade essays on The Iliad? Neither do I. Do you want to let 10th graders do the essay untimed at home and then try to catch all the plagiarism? Neither do I.)

2. College writing courses aren’t about writing.
I once attended a university-sponsored training session called “Creating Outcome Assessments for Writing Assignments.” Anyone teaching a writing course was invited, and about 25 teachers were there. We each introduced ourselves and named the course we were teaching. I was the only person whose course title included the word “writing.” The others were teaching history, literature, sociology, and so on. But each course required a paper, so it was a “writing” course. I realized they weren’t teaching writing; they were teaching history (or whatever) and had to give a writing assignment.

So who’s teaching writing? Maybe all the writing teachers already knew how to create an outcome assessment, so they had no need for the training, and that’s why none of them were there. Maybe. Or maybe there are very few classes that actually focus on teaching writing.

3. Master’s classes aren’t about writing.
One of my students told me no one had ever commented on her writing to the degree her legal-writing teachers had. In earning her master’s degree, she had written a lot of papers and a lot of essays, but she almost never got mechanical or structural comments on them. What was most important, she learned, was that the paper presented a great idea, an original idea, something new. That’s what mattered.

Of course, the paper couldn’t be sloppy, full of writing errors. But no one in her program was concerned about that; they were all average to above-average writers. So although the course grade was based almost entirely on writing papers, there was no classroom instruction on writing and very little feedback on the actual writing the students did.

My point?

Many of us assume someone else taught students how to write. We look backward to college, to high school, to middle school. We assume someone taught them writing. We assume they learned it. We assume they know the basics (and some of us define the basics fairly comprehensively, possibly forgetting what we once didn’t know). But what if no one ever taught them writing? I’m beginning to think no one ever did.

And why not?

Maybe it’s because teaching writing is a pain in the neck. It’s hard, and it’s easier and more interesting to focus on something like The Iliad or history or a new idea. It’s easier to assume someone else taught them writing, so we don’t have to.


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Don’t Rest on Plateaus

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Are the legal-writing classes you had in law school the last writing training you’ll need for your career?

If you’re a bankruptcy lawyer, was a law-school class the last bankruptcy training you’ll need?

That’s your answer. Legal writing is like any skill or substantive topic: there’s always more to learn, and there’s always room for improvement. But sometimes, busy legal writers rest on plateaus. We produce good-enough legal writing, and we’re comfortable on that plateau, so we stay. Here’s some advice for moving on.

1. Admit you have room to improve. When I was a full-time lawyer, I thought I was a good writer, above average. Now I realize I hadn’t been that good. I’d been quite mediocre. I was poorly educated about the standards of high-level professional writing, and I was ignorant of my own limitations. Was I unique? Probably not. Many lawyers believe themselves to be good writers, above average within the profession, but I say this: The first step to becoming a good legal writer is to admit you have room to improve.

2. Get some references. Once you’ve admitted you have room to improve your writing—that you’re resting on a plateau—start learning. A great way to raise your writing IQ is to consult the experts. When you have a question about writing, don’t rely on half-remembered “rules” from high-school English. Look it up. But where? Here are two websites I like:

But if you’re serious about legal writing, you’ll need some reference books, and here are three I recommend:

  • The Redbook, by Garner
  • The Texas Law Review Manual on Usage and Style
  • Just Writing: Grammar, Punctuation, and Style for the Legal Writer, by Enquist & Oates

Your goal is to have reliable references handy to answer questions. Other professional writers consult writing references, and lawyers should, too.

3. Read writing books. If you’re serious about getting off that plateau, you’ll have to do more than consult references. You’ll have to study the principles of good writing and good legal writing. But how, when you’re busy? Set a goal to read one book on writing every year. Here are some I like

  • Lifting the Fog of Legalese, by Kimble
  • The Lawyer’s Guide to Writing Well, by Goldstein & Lieberman
  • Writing with Style, by Trimble.

These books are great sources of writing knowledge, and they’re also well written. Reading the best books teaches you writing and exposes you to good writing.

4. Practice what you learn. You’re reading about writing and you’re consulting writing references. Now practice what you’re learning. Of course, for any working lawyer, writing practice is part of the job: you’re writing all the time. Yet we tend to rest on plateaus—we write as we always have, with the same habits, the same limitations. (That’s why studying writing is so important. Practice without study is usually just repetition.) So experiment with things you’re learning. Try new techniques and master new approaches to writing.

5. Edit better. We all know editing is crucial to good writing. Most of us can’t produce high-quality writing in one draft (or even two). We must edit, so here are some suggestions for getting off the editing plateau.

Leave plenty of time, even though it’s hard to do. How much? One pro recommends half the time on a writing project. Debra Hart May, Proofreading Plain and Simple 46 (1997).

Use more than one technique when editing: Do you edit on the computer screen? That’s fine, but it’s not enough. Do some editing on a hard copy, too; we read and react differently to screen text and printed text. Do you read the text out loud? That’s great: you’re using your ears, not just your eyes, to help you edit. Now go further and have a trusted colleague read it and suggest some edits. Do you read the document in reverse, from the last sentence to the first? Good. This technique tricks your mind, so you’re not familiar with the text; familiarity leads to poor editing. Now read only the topic sentences. Next read the opening and closing paragraphs.

Mediocre writing becomes good writing only through editing.

6. Accept critique. Here’s the hardest part: seek and welcome critiques and candid suggestions for improving your writing. This one’s tough because it’s natural to be defensive about your writing—maybe even insecure. I know I am. But when I avoid critique, I don’t improve much. I rest on a plateau. So open yourself to honest critique. Find a trusted colleague, friend, or supervisor, someone whose judgment and writing you respect. Then ask for suggestions, and take them to heart. The best writers are open to critique.

Now move off that plateau.


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Simplicity, clarity, and plainness

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“Simplicity is widely praised and narrowly practiced.” Robert Gunning, The Technique of Clear Writing 68 (1968).

In legal writing, this truth applies to clarity and plainness: many recommend them; few execute.

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