As I wrote in a post back in January, in State v. Cady, 2018 UT App 8, the Utah Court of Appeals joined the growing number of courts using the parenthetical “(cleaned up)” to “clean up” citations to quoted material. A few months after Cady, in State v. Gonzales-Bejarno, 2018 UT App 60, the court used the parenthetical “quotation simplified” in place of “cleaned up.” Id. ¶ 12. With a nod to Cady, it noted, “[t]he court’s internal style guide has adopted the parenthetical “quotation simplified” in the spirit of the nascent “cleaned up” parenthetical.” Gonzales-Bejarno, 2018 UT App 60, ¶ 12 n.3.
Since then, the court has been liberal in its use of the parenthetical, as shown in the following cases:
- Kirkham v. McConkie, 2018 UT App 100
- State v. Guzman, 2018 UT App 93
- True v. UDOT, 2018 UT App 86
- State v. Norton, 2018 UT App 82
- State v. Brocksmith, 2018 UT App 76
- State v. Peraza, 2018 UT App 68
- Pulham v. Kirsling, 2018 UT App 65
- State v. York, 2018 UT App 90
- Gerwe v. Gerwe, 2018 UT App 75
- State v. Whitbeck, 2018 UT App 88
- Palmer v. St. George City Council, 2018 UT App 94
- NPEC LLC v. Miller, 2018 UT App 85
- Berrett v. State, 2018 UT App 55
- State v. Becker, 2018 UT App 81
- Blackhawk Townhouses Owners Ass’n v. J.S., 2018 UT App 56
- Munoz-Madrid v. Carlos-Moran, 2018 UT App 95
- State v. Rinehart, 2018 UT App 87
- State v. Mooers, 2018 UT App 74
- Basin Auto Paint Specialists Inc. v. Ultimate Autobody & Accessories LLC, 2018 UT App 72
- Boyle v. Clyde Snow & Sessions PC, 2018 UT App 69
So even as “cleaned up” grows in popularity with courts across the country, “quotation simplified” has become the parenthetical of choice in the Utah Court of Appeals for cleaning up quotations.