Words. Grammar Rules

• Author: Bryan A. Garner
• Pages: 34-35

WORDS

Grammar

Rules

The case of the unhyphenated

phrasal adjectives

BY BRYAN A. GARNER

IN THE SUPREME COURT

OF JOURNALISTIC ERRORS

SHORT-DASH v.

BLUNDERBUSS CLARION

Before Sterling, C.J.; Fussbudget, J.;

Anomie, J.; Martinet, J.; and Wafer, J.

Syllabus

Before this Honorable Court is the

complaint of Marian Short-Dash, who

accuses her local newspaper, the Blun-

derbuss Clarion, of omitting “obliga-

tory hyphens” from phrasal adjectives,

thereby impairing her ability to read

without annoyance.

In particular, she cites three phras-

es that recently appeared on a single

page: (1) an op-ed promoting “hate free

speech” (she wants it to be “hate-free

speech”); (2) another relating to “tax

and spend politicians” (she wants it to

be “tax-and-spend politicians”); and

(3) a reference to “federally recognized

Indian tribes” (she wants it to be “feder-

ally-recognized tribes”).

The trial court sustained all three

complaints. AFFIRMED as to the rst

and second counts; REVERSED on

the third.

Chief Justice Sterling wrote the opin-

ion of the court, joined by Justices Fuss-

budget and Martinet. Justice Fussbud-

get led a separate concurring opinion.

Justice Martinet led an opinion

concurring in part and dissenting in

part. Justice Anomie led a dissenting

opinion. Justice Wafer led a dissent-

ing/concurring opinion.

STERLING, C.J.

We are asked to decide the mandato-

ry or nonmandatory status of hyphens

in phrasal adjectives, also known as

compound modiers. In the absence of

a statutory mandate, we address this

as a common-law issue. (Note that the

dissenter would call this a common law

issue. While it is indeed common, it is

not necessarily a “law issue.”)

The precedents are numerous

and varied.

In our own opinions, we refer to

bench trials (it’s a noun phrase) but

to bench-trial strategies (the phrase is

being used as an adjective); to joint

ventures but to joint-venture issues; to

the law of the case but to the law-of-

the-case doctrine.

When writing about oil-and-gas

issues (did you see that?), we refer to

cessation-of-production clauses. And

we’ve been known, in admiralty cases,

to refer to the no-lien-for-partial-exe-

cution-of-affreightment-contracts rule.

These practices were established by

our splendid in-house copy editor, who

continues to uphold our long-stand-

ing tradition even when counsel and

law-review commentators neglect

the hyphens.

One usage critic wrote long ago that

the omission of the hyphen marks the

“incompetent amateur.” Wilson Follett,

Modern American Usage 428 (1966).

Another has stated that the omission of

these hyphens creates “a dull headache

[, which] is the least of the evils.” H.

George Classen, Better Business English

69 (1966). A more recent authority,

The Wall Street Journal Essential Guide

to Business Style and Usage (2002),

recommends hyphenating high-school

students, real-estate dealers and feder-

al-funds rate (page 118).

Why hyphenate high-school stu-

dents? Is it really possible that some-

one would think, in the absence of the

hyphen, that the students are high on

something?

Photo illustration by Sara Wadford/Shutterstock

Practice Matters | WORDS

ABA JOURNAL | APRIL–MAY 2022

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