How do you reduce word counts, remove extraneous information, and declutter your briefs? Simple. Clean up your parentheticals with (cleaned up).
On January 11, 2018, the Utah Court of Appeals issued State v. Cady, 2018 UT App 8, and in the process joined the growing number of courts climbing on-board the (cleaned up) citation movement. See State v. Cady, 2018 UT App 8, ¶ 10. At paragraph 10 of its opinion, the court quoted from the Utah Supreme Court’s opinion in State v. Bagnes, 2014 UT 4, ¶ 10, 322 P.3d 719. The quote in the Bagnes opinion was this:
we may reverse only when “it is apparent that there is not sufficient competent evidence as to each element of the crime charged.” State v. Boyd, 2001 UT 30, ¶ 13, 25 P.3d 985 (internal quotation marks omitted). Our review of the evidence itself is deferential. See State v. Dunn, 850 P.2d 1201, 1212 (Utah 1993). We may reverse a verdict ―only when the evidence, so viewed, is sufficiently inconclusive or inherently improbable such that reasonable minds must have entertained a reasonable doubt that defendant committed the crime for which he or she was convicted.” Id.
So normally, your citation would look something like this: State v. Bagnes, 2014 UT 4, ¶ 10, 322 P.3d 719 (quoting State v. Boyd, 2001 UT 30, ¶ 13, 25 P.3d 985 (internal quotation marks omitted) (quoting State v. Dunn, 850 P.2d 1201, 1212 (Utah 1993)).
Employing the (cleaned up) citation method, the quotation and accompanying citation in Cady became this:
we may reverse only when it is apparent that there is not sufficient competent evidence as to each element of the crime charged. Our review of the evidence itself is deferential. We may reverse a verdict only when the evidence, so viewed, is sufficiently inconclusive or inherently improbable such that reasonable minds must have entertained a reasonable doubt that [the] defendant committed the crime for which he or she was convicted.
State v. Bagnes, 2014 UT 4, ¶ 10, 322 P.3d 719 (cleaned up)