I wrote in a post back in January 2018 that the Utah Court of Appeals had joined the growing number of courts across the nation using the parenthetical (cleaned up). In a nutshell, (cleaned up) is used “to indicate that internal quotation marks, alterations, and/or citations have been omitted from a quotation.” State v. Cady, 2018 UT App 8, ¶ 9 n.2. A few months later, as I explained in this post, the Utah Court of Appeals adopted the parenthetical (quotation simplified) in place of (cleaned up).
The court of appeals explained that (quotation simplified) was now part of its internal style guide. See State v. Gonzales-Bejarno, 2018 UT App 60, ¶ 12 n.3. But Judge Mortensen remained steadfast in using (cleaned up) even after that pronouncement. See, e.g., Warrick v. Property Reserve, Inc., 2018 UT App 197, ¶¶ 6, 12, 18, and 19 (using (cleaned up)).
The matter was ripe for the Utah Supreme Court to weigh in. It now has. And the winner is (cleaned up). See Salt Lake City v. Kidd, 2019 UT 4, ¶ 14.
Though I have used (quotation simplified) in briefs to the Utah Court of Appeals, given the widespread use of (cleaned up) and the Utah Supreme Court’s apparent adoption of the parenthetical, it is likely the better choice. And if you’re still on the fence about whether to use the parenthetical at all, remember that the Bluebook gobbledygook—(citing this) (quoting that) (alternations original) (blah blah blah)—counts against your allotted number of words and lengthens each page of your argument with unnecessary verbiage and clutter. Get on board.