When To Spell Out Numbers In Legal Writing

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Here are some writing tips from the leading legal writing style guide, The Redbook / A Manual On Legal Style by Bryan Garner. Our topic today is numbers.

The Redbook generally follows AP in the basics: spell out one through nine and use numerals for 10 and above. Here are some other rules from The Redbook:

Numerals in citations. Numbers in citations are always written as numerals unless they are part of a title.

In titles. Repeat a title as it is written, regardless of what convention you use for your own text.

Ex.: She was reading The 7 Habits of Highly Effective Editors.
Ex.: Gabriel Garcia Marquez, One Hundred Years of Solitude 56 (1998).

If one item of a kind should be in numerals, then use numerals for all items of that kind in the immediate context.

In series. If one item in a series should be in numerals, use numerals for all the items. Example: The convicted robber drew concurrent sentences of 8, 8, and 12 years for the three incidents.
In proximity. Even if not strictly in series, numbers that denote the same type of thing should usually be in the same format. But be reasonable and ignore this guidance if the result would be absurd.
- Ex.: In 1960 there were 5 lawyers in this county; today there are 125.
- Ex.: You can't see the next town, which is just five miles down the road, but you can see the sun, which is 93 million miles away.

If two numbers that are not of the same kind appear next to each other, one (usually the first) should be spelled out to avoid confusion.

First number. Usually, it is the first number that is spelled out.
- Ex.: The package contained fifty $20 bills. (Normally, we would write 50.)
Second number. But if the second number is an ordinal or part of the adjective phrase, it may be spelled out instead.
- Ex.: We have 256 one-L students this year. (But: We have three 1L representatives on the Student Bar Association.)
- Ex.: The team's roster swelled with 17 second-round draftees.
- Ex.: We are honoring fifteen 4.0-GPA graduates today.

Use numerals for statute, volume, chapter, and section numbers; in tables; in dates and times; for money; with units of measurement; in decimals; and in names of roads, military divisions, and the like.

Count and series. In general, numerals are used with count nouns and where the numbers appear in series.
- Ex.: Title 28 of the U.S. Code
- Ex.: § 1983
- Ex.: Chapter 11
- Ex.: July 4, 1776 (but the Fourth of July)
- Ex.: 5:15 p.m. (but five o'clock shadow)
- Ex.: 6%
- Ex.: 32°F
- Ex.: 1.414
- Ex.: I-495
Exceptions for names. Some names contain numerals or spelled-out numbers; others are spelled out by convention. Use the preferred name despite any style rule to the contrary.
- Ex.: 1st Infantry Division (but The Big Red One)
- Ex.: First Division, Army of Northern Virginia
- Ex.: the Fourteenth Amendment (by convention)
- Ex.: the Eleventh Circuit
Other exceptions. By convention, the ordinal designations of centuries and amendments to the U.S. Constitution are spelled out.
- Ex.: twentieth century
- Ex.: Fourteenth Amendment

In legal writing, spell the ordinal numbers 2d and 3d, not 2nd and 3rd.

Legal convention. This legal convention applies as well to larger numbers ending in 2 and 3.
- Ex.: Lee v. Bankers Trust Co., 166 F.3d 540 (2d Cir. 1999).
- Ex.: The law was passed by the 92d Congress.
General convention. Outside legal contexts, use the generally accepted spellings, 2nd and 3rd.
- Ex.: The picketers joined hands and recited the 23rd Psalm as police began to make arrests.
- Ex.: The musical is playing in the theater on 42nd Street.

Source: The Redbook / A Manual On Legal Style, by Bryan A. Garner.

Topics: writing numbers, numbers