Melanie Kalmanson is a commercial litigation attorney and former Florida Supreme Court law clerk. She is the author of the Bluebook Wednesday Tips Newsletter. Click here to subscribe to Melanie’s newsletter.
Tip #4, Direct Quotes – Brackets (Rule 5.2)
Use brackets where you change the capitalization of a letter, add a letter(s), change a letter(s), add a word(s), or change a word(s).
You also use brackets to show you’ve removed a letter(s) but not to show you’ve removed a word(s). Removing words is shown with ellipses, which is Tip #5.
A good use for brackets is changing the tense of the direct quote to make it fit in the context.
Original: “Plaintiff appeals the trial court’s order granting summary judgment for Defendants.” Brackets: “Plaintiff appeal[ed] the trial court’s order granting summary judgment for Defendants.”
Another good use for brackets is adding information. In my simple example…
Original: “Plaintiff appeals the trial court’s order granting summary judgment for Defendants. Brackets: “Plaintiff appeal[ed] the trial court’s order granting summary judgment for Defendants [on all counts raised in Plaintiff’s Complaint].”
Probably the most common way I use brackets is to change capitalization. This example shows that and adds a word for the context.
Original: “The Motion was filed on September 26, 2021.” Brackets: The trial court's order was issued on March 4, 2022, disposing of “[t]he Motion [that] was filed on September 26, 2021.”
Also, a great point by Jamie Szal and confirmed by Jonathan Graham that you don’t need to make any additional notation when you alter the quote with brackets.
