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Important abbreviation information

What is the proper Bluebook abbreviation for the federal district courts of the Northern and Southern Districts of West Virginia? This question seems like it should have a simple answer, but I haven’t been able to find one.*

According to rule 10.4, courts are abbreviated “according to tables T1 or T2 if included therein and according to tables T7 and T10 in all other cases.” Additionally, rule 10.4(a) gives three examples of federal district court abbreviations: “D.N.J.,” “D.D.C.,” and “C.D. Cal.” Table T1.1 gives two further examples: “D. Mass.” and “S.D.N.Y.” The pattern here seems fairly clear: combine the court abbreviation from table T7 and the jurisdiction abbreviation from table T10. Table T7, of course, tells us that “Southern District” is “S.D.” and “Northern District” is “N.D.” And table T10 tells us that “West Virginia” is “W. Va.”

So for the Southern District, we’ve got to smush “S.D.” and “W. Va.” together. According to rule 6.1(a), “[i]n general, close up all adjacent single capitals . . . [b]ut do not close up single capitals with longer abbreviations . . . .” Taking that rule literally, the result would be “S.D.W. Va.”

According to my best reading of the rules, that’s the answer, right there. The problem is that that’s a horseshit abbreviation. The “W.” belongs with the “Va.”; it’s got no business snuggling up to the “S.D.” instead. It looks like the S.D.W. of Virginia (whatever that would be) rather than the S.D. of West Virginia.

Now, rule 6.1(a) also says, “[i]n abbreviations of periodical names . . . , close up all adjacent single capitals except when one or more of the capitals refers to the name of an institutional entity, in which case set the capital or capitals referring to the entity off from other adjacent single capitals with a space.” For example, one writes “N.Y.U. L. Rev.” rather than “N.Y.U.L. Rev.” One could adapt that rule for this situation as well, in which case the abbreviation would be “S.D. W. Va.” That’s all well and good as far as it goes, but the rule specifically refers to periodical names; we’re taking liberties applying it to a court.

So, the prescriptive approach has failed; let’s go descriptive. What I’d like to do is search for the relative prevalence of “S.D.W.Va.,” “S.D.W. Va.,” “S.D. W.Va.,” “S.D. W. Va.,” “S. D. W.Va.,” “S. D. W. Va.,” etc., but, unfortunately, search engines seem to consider each of these strings to be identical, so figuring out which abbreviation is most popular is not a trivial matter. Nevertheless, in the interest of science (or whatever), I have conducted some empirical research.

Specifically, I visited the websites of the Southern and Northern Districts to review their recently published decisions. For each judge with opinions published on the court’s website within the past three years, I found the most recent opinion that cited to either of the federal district courts in West Virginia. The results were less than illuminating.

The two leading abbreviations in the Southern District appear to be “S.D.W. Va.” (by the book) and “S.D. W. Va.” (the periodical analogy), the former used by Chief Judge Chambers in a 2015 opinion and by Judge Faber in a 2015 opinion, and the latter used by Judge Goodwin in a 2016 opinion and by Judge Johnston in a 2013 opinion. Blazing her own trail, Magistrate Judge Eifert used “S.D.W.Va.” and “N.D.W.Va.” (getting rid of the space altogether!) in a 2015 opinion.

(I should acknowledge at this point that I am not laboring under the delusion that many of these judges are likely to be entirely consistent in their own usage. But honestly this has already taken way too long as it is.)

Anyway, there’s clearly no consensus in the Southern District. Onto the Northern.

The clear winner in the N.D. is the periodical-style “N.D. W. Va.”/”S.D. W. Va.,” which was used by Chief Judge Groh in a 2016 opinion, by Judge Stamp in a 2016 opinion, by Magistrate Judge Joel in a 2013 opinion, and by Magistrate Judge Trumble in a 2016 opinion.

The by-the-book “N.D.W. Va.” was used only by Judge Keeley, in a 2016 opinion. (However,  Magistrate Judge Kaull used “N.D.W Va.” [sic] in a 2015 opinion, which I guess is pretty close.)

Additionally, the Northern District has apparently innovated their own abbreviation, which doesn’t look so bad but is also clearly wrong: “N.D. W.Va.”/”S.D. W.Va.” This one was used by Judge Bailey in a 2016 opinion and by Magistrate Judge Seibert in a 2016 opinion.

Finally, Magistrate Judge Aloi tries to have it both ways in a 2016 opinion, in which he used both the N.D.’s innovative “N.D. W.Va.” and the periodical-style “S.D. W. Va.”

So, to recap, we have the following possibilities:

S.D.W.Va.
Pros: concise, used by at least one magistrate judge
Cons: violates table T10

S.D.W. Va.
Pros: perhaps technically correct, used by several judges
Cons: intuitively wrong

S.D. W.Va.
Pros: unique (?), used by some judges
Cons: obviously wrong

S.D. W. Va.
Pros: intuitively correct, used by plurality of judges (in my not-at-all scientific survey)
Cons: no clear justification under the Bluebook

I think I’ll be using “S.D. W. Va.,” although I don’t think there’s a clear winner here. Do what you feel.

* I feel compelled to clarify that I’m not asking the question because I’m afraid of using the “wrong” citation. I just think it’s anomalous that an apparently exhaustive citation guide like the Bluebook would not have a clear answer to a question that must come up literally every day (for some people, anyway).

Fake Uber lawsuit obviously filed by Jonathan Lee Riches

UPDATED BELOW (02/15/17)

The media is apparently mystified by the pro se lawsuit supposedly filed by accused Uber shooter Jason Brian Dalton. At this time no one is reporting that the lawsuit was obviously filed by Jonathan Lee Riches. You heard it here first.

First, any connoisseur of Riches’s work would recognize his inimitable style.

Second, as noted in the news story linked above, one of the key pieces of evidence showing that the suit was not actually filed by Dalton was its Philadelphia postmark. (Dalton is incarcerated in Michigan.) Guess who is currently incarcerated in Philadelphia? (Hint: Enter jonathan lee riches into the Find By Name fields.)

Third, another piece of evidence noted in the news story was the mismatch between the handwriting on the complaint versus Dalton’s own handwriting. Well, here’s the first page of the “Dalton” complaint, and here’s the first page of Riches’s earlier complaint against the Guinness Book of World Records. The Dalton complaint appears to have been written in more of a hurry, but the hand looks like a match to me.

Troll on, Johnny Suenami.

 

UPDATE: I see that The Smoking Gun pieced this together the same day I did. Needless to say, my post was up before TSG’s, but I’m sure they came by their conclusions independently…

(Also, J.L.R. got out. The inmate-locator page linked above is no longer useful.) –m.b.

Dana Miltank

Important comma information

UPDATED BELOW (12/14/16)

I ran across this blog post today, then read the unusually incisive (you know, for the Internet) comment, and decided that more research was necessary to really get to the bottom of things.

An hour and a half later, here are the facts.

According to Strunk and White (4th ed.), “If a dependent clause, or an introductory phrase requiring to be set off by a comma, precedes the second independent clause, no comma is needed after the conjunction.” Thus, for example: “The situation is perilous, but if we are prepared to act promptly, there is still one chance of escape.”

According to the Chicago Manual of Style (16th ed.), “When two conjunctions appear next to each other (e.g., and if, but if), they need not be separated by a comma.” Thus, “Burton examined the documents for over an hour, and if Smedley had not intervened, the forgery would have been revealed.” And, “They decided that if it rained, they would reschedule the game.”

The important thing to see here is that these are not the same rule.

S&W talks about dependent clauses or introductory phrases. Chicago is concerned with two conjunctions in a row. These two situations can, but certainly do not necessarily, coincide.

Here are a few examples that bear this out.

1: “The situation is perilous, but if we are prepared to act promptly, there is still one chance of escape.” [S&W & Chicago agree that no comma is necessary before if. I personally think the absence of the comma looks bad, but I am not a recognized authority on anything.]

2: “They decided that if it rained, they would reschedule the game.” [Chicago says this is correct. S&W does not appear to address this type of sentence and perhaps would insert a comma before if. If so, I’m on S&W’s side here.]

3: “Commas are great, and, in my opinion, we should use them as often as possible.” [S&W’s rule says that there needn’t be a comma before in. Chicago’s rule does not address this sentence. Based on similar sentences found in the Manual itself, I think Chicago would agree that I punctuated it correctly.]

I hope anyone at all in the world finds this helpful.

 

UPDATE: Through a combination of fortune and skill, I have recently acquired a copy of Bryan Garner’s Chicago Guide to Grammar, Usage, and Punctuation. I am sad to report that the section on commas is fully silent on this issue. –m.b.

UPDATED: Rebranding

This blog is abruptly switching formats from juvenile sex-related humor to resolving important punctuation questions. Further bulletins as events warrant.

You need a trip to Nintendo Land for a crash course in KNOWLEEEEEEEEEEEDGE!

Although the video is just a parody of 90’s sex-ed videos, it’s worth a watch. Highlights include Luigi’s voice, Mario’s moustache becoming pubic hair, Peach’s breast development, and “my little garbanzo bean.”

CYBORGASMATRIX

That’s right, everyone. While we’re on the topic of horrifying sex dolls (thanks, Paul) I need to show you the CYBORGASMATRIX. The CYBORGASMATRIX. It has EYES and a MOUTH and TITTIES.

TITTIES. It’s advertised as the most sophisticated sex doll in history. And it has TRIPLE H TITTIES. Created from a life-size cast of porn actress PANDORA PEAKS. It has a prerecorded voice.

The standard model will set you back 5500 dollars, what with the armless, legless torso, and the TITTIES.

Paul, you started this. Look what you did.

You guys, I think this should be the last entry we ever do on sex dolls.  If we want this to be not a terrible blog of shit.

$50.00 SAMPLE PUSS AND NIPPLES $50.00

The FemSkin is an “anatomically correct flesh like silicone [sic] skin bodysuit in a perfect female form.” Atrocious site design aside, this discovery is indeed one of the creepier things to come out of the Internet this week. It’s basically a giant rubber suit for men that will mold your body into a vile pastiche of the female form, complete with an “insertable rectum for the anus.” In fact, FemSkin apparently produces an entire line of “transgender prosthetics” that you can slap onto your disgusting, fat, hairy body to feel like a woman. Now, I have nothing against the transgender crowd, but this is just wrong. Also, it reminds me of the “woman suit” Buffalo Bill made in The Silence of the Lambs.

Dude with face