Thoughts on Legal Writing from the Greatest of Them All: William Strunk Jr. & E.B. White—Part I

By Gerald Lebovits


William Strunk Jr. earned a Ph.D. from Cornell University in 1896 and taught English there for more than 40 years. He wrote and published “The Elements of Style,” a grammar rulebook, for use in his Cornell English class.[1] The “little book,” as Strunk and his students called it, discussed core principles of usage, composition and form. It also reviewed commonly misused words and expressions.

In 1919, a student named Elwyn Brooks White used the little book in Strunk’s course. White recalls Strunk as an avid admirer of “the clear, the bold, and the brief,” characteristics the little book embodied.[2] According to White, Strunk was most passionate about Rule 17, “Omit needless words.” He “put his heart and soul” into teaching his students the importance of Rule 17.[3]

After passing Strunk’s class, White had forgotten the little book but not his memorable English professor. White went on to an illustrious career as an acclaimed writer for The New Yorker and published notable works like “Stuart Little” and “Charlotte’s Web.”[4] White revisited Strunk’s little book four decades after Strunk’s class, when Macmillan Publishers asked White to revise it for college students and the general market.

White described the little book as a “forty-three-page summation of the case for cleanliness, accuracy, and brevity in the use of English.”[5] The original book contains Strunk’s principles on proper grammar; White sought to preserve his professor’s dedication and vigor in his revision. White added a chapter, “An Approach to Style,” exploring the mystery of style and distinguished writing.[6] Strunk had passed away by the time White revised the book. But Strunk’s legacy continues through his students and his little book.

In this two-part column we highlight Strunk and White’s principles of writing as expressed in their book, “The Elements of Style.” In Part I, we’ll address Strunk’s recommendations on usage and composition. In Part II, we’ll address White’s suggestions on effective style, Strunk’s principles on form and his critique of commonly misused words and expressions.


Strunk dedicated Rules 3, 4, 5, and 6 to proper punctuation. He urged his readers to internalize these rules so that they become “second nature” to them.[7] We’ll obey Strunk’s command.

Rule 1: Form the Possessive Singular of Nouns by Adding ’s

Strunk told writers to “[f]ollow this rule whatever the final consonant.”[8] For example, the possessive singular of the noun Charles is “Charles’s friend.”[9] An exception, he explained, is for historical figures like Moses: Moses’ book. Indefinite pronouns like “one’s rights” likewise require an apostrophe to show possession.[10] Strunk cautioned writers to avoid the most common error in the English language: writing it’s for its, or vice versa.[11] It’s is a shorter version for “it is,” and its is a possessive.[12]

Rule 3: Enclose Parenthetic Expressions Between Commas

Strunk observed that Rule 3 is difficult to follow: It might not be clear whether a word or phrase is parenthetic and therefore requires a comma. The rule is easier to follow when the writer uses a name or title in direct address.[13] For example, “Well, Susan, this is a fine mess you’re in.” Abbreviations such as etc., i.e., and e.g. are also parenthetic and warrant a comma.[14] Nonrestrictive relative clauses are parenthetic, too; they don’t “identify or define the antecedent noun” but “merely add something.”[15] Example: “The audience, which had at first been indifferent, became more and more interested.”[16] The clause starting with which adds nothing; thus, you should include a comma. Restrictive clauses, on the other hand, don’t require a comma and aren’t parenthetic; they define the antecedent noun.[17]

Consider this: “People who live in glass houses shouldn’t throw stones.”[18] The clause starting with who tells the reader which people the writer is referring to. In situations of uncertainty, Strunk instructed writers never to “omit one comma and leave the other.”[19]

Rule 4: Place a Comma Before a Conjunction Introducing an Independent Clause

“Two-part sentences of which the second member is introduced by as (in the sense of ‘because’), for, or, nor, or while (in the sense of ‘at the same time’) likewise require a comma before the conjunction.”[20] Similarly, if the subject of two clauses is the same and expressed only once, a comma is effective if it’s separated by the conjunction but.[21] Example: “I have heard the arguments, but am still unconvinced.”[22] A comma isn’t required when two clauses are strongly related and the conjunction is and.[23] For example, “He has had several years’ experience and is thoroughly competent.”[24]

Rule 5: Don’t Join Independent Clauses with a Comma

Strunk declared that when a sentence consists of two or more grammatically correct clauses not joined by a conjunction, the proper punctuation is a semicolon.[25] For example, “Mary Shelley’s works are entertaining; they are full of engaging ideas.”[26] This is especially true if both clauses relate to the same idea or when the writer uses an adverb such as accordingly, besides, then, therefore, or thus before the second clause.[27] Being able to identify the relationship between clauses is integral to composition, Strunk explained.

Rule 6: Don’t Break Sentences in Two

Strunk urged writers to avoid substituting periods for commas. If the writer seeks “to make an emphatic word or expression serve the purpose of a sentence,” using a period for a comma is permissible so long as the “emphasis is warranted.”[28]

Rule 9: The Number of the Subject Determines the Number of the Verb

“Words that intervene between subject and verb do not affect the number of the verb” because a “singular subject remains singular even if other nouns are connected to it by with, as well as, in addition to, except, together with, and no less than.”[29] Strunk also cautioned writers to avoid using a singular verb after the expression “one of” or similar expressions, when the subject warrants a plural verb.[30] For example, “One of those people who is never ready on time” should be written as “One of those people who are never ready on time.”[31] Rule 9 is difficult to apply, but Strunk gave clear examples. In the case of pronouns like each, either, everyone, everybody, neither, nobody, someone, a writer should always use a singular verb.[32] If “a compound subject [is] formed of two or more nouns joined by and,” the correct usage is a plural verb unless the compound subject is “considered a unit,” in which case a writer should use a singular verb.[33] Example: “Give and take is essential to a happy household.”[34] “Give and take” is a unit; a writer should use a singular verb.

There might be some times where a noun appears plural but is really singular, and therefore warrants a singular verb. In these situations, Strunk noted, a writer “must simply learn the idioms.”[35]


Rule 12: Choose a Suitable Design and Hold to it

For effective writing, according to Strunk, one must be able to follow the writer’s thoughts. The writer must determine “the shape of what is to come and pursue that shape.”[36] If the writer chooses a suitable design and holds to it, the writing will be much more effective, and the reader will know where the writer is headed. Thus, “planning must be a deliberate prelude to writing.”[37]

Rule 13: Make the Paragraph the Unit of Composition

Strunk noted that a “paragraph is a convenient unit” serving “all forms of literary work.”[38] There’s no clear-cut rule about how long a paragraph should be; “as long as it holds together, a paragraph may be of any length.”[39] If a writer intends to write a brief synopsis of a movie, a single paragraph might be appropriate. If a writer is writing a legal brief or an argumentative paper, the writer should divide the subject “into topics each of which should be dealt with in a paragraph,” beginning “each paragraph either with a sentence that suggests the topic or with a sentence that helps the transition.”[40] This technique “aids the reader” by indicating “that a new step in the development of the subject has been reached” and making clear the “relation [of the paragraph] to what precedes or its function as part of the whole.”[41]

Additionally, to “aid the reader,” it might be appropriate to break long paragraphs into two even if the writer isn’t required to do so, because it “is often a visual help.”[42] Nevertheless, Strunk argued, “moderation and a sense of order should be the main considerations in paragraphing.”[43]

Rule 14: Use the Active Voice

Strunk explained that using the active voice “makes for forcible writing.”[44] Writing will be more concise, vigorous and direct than with the passive voice. Strunk also argued that the active voice tends to form shorter, stronger sentences because “brevity is a by-product of vigor.”[45] Strunk cautioned, however, that a writer shouldn’t entirely abandon the use of passive voice; they’re sometimes convenient and necessary.[46] But in most cases, a writer should use the active voice to achieve clarity and concision.

Rule 15: Put Statements in the Positive

Strunk advised writers to “[m]ake definite assertions” and to “[a]void tame, colorless, hesitating, noncommittal language.”[47] Specifically, writers must avoid auxiliaries like would, should, could, may, might and can, unless the subject involves genuine uncertainty.[48] If not, Strunk argued, “your writing will lack authority.”[49] For example, “He was not very often on time” becomes “He usually came late.”[50] “[I]t is better to express . . . a negative in positive form.”[51]

Rule 16: Use Definite, Specific, Concrete Language

Strunk urged writers to “[p]refer the specific to the general, the definite to the vague, the concrete to the abstract.”[52] This technique will “arouse and hold the reader’s attention.”[53] To comply with Rule 16, writers needn’t include every detail, but only those “significant details . . . with such accuracy and vigor that readers, in imagination, can project themselves into the scene.”[54]                       

Rule 17: Omit Needless Words

Here’s some classic advice: “Vigorous writing is concise. A sentence should contain no unnecessary words, a paragraph no unnecessary sentences, for the same reason that a drawing should have no unnecessary lines and a machine no unnecessary parts.”[55] A writer mustn’t be wordy. Strunk instructed writers to resist the temptation to use expressions like owing to the fact that, in spite of the fact that, and, most important, the fact that, “an especially debilitating expression.”[56] Strunk argued that writers “fall into wordiness” because they improperly use more than one sentence to explain a single complex idea that could be expressed in one sentence. Writers must ensure that “every word tell[s].”[57]

This column continues in the next edition of the Journal with Part II, in which we’ll address White’s recommendations on effective style and Strunk’s principles on form and commonly misused words and expressions.

Gerald Lebovits ([email protected]), an acting Supreme Court justice in Manhattan, is an adjunct at Columbia, Fordham, and NYU law schools. For his research he thanks Bayron Flores Tapia (Fordham University School of Law), his judicial fellow.

[1] Sam Roberts, “The Elements of Style” Turns 50, N.Y. Times (Apr. 21, 2009),

[2] William Strunk Jr. & E.B. White, The Elements of Style xviii (4th ed. 2000).

[3] Id. at xv.

[4] Id. at x.

[5] Id. at xiii.

[6] Id. at xiv.

[7] Id. at 7.

[8] Id. at 1.

[9] Id.

[10] Id.

[11] Id.

[12] Id.

[13] Id. at 3.

[14] Id. at 2–3.

[15] Id. at 3–4.

[16] Id. at 4.

[17] Id.

[18] Id.

[19] Id. at 2.

[20] Id. at 5.

[21] Id.

[22] Id.

[23] Id.

[24] Id.

[25] Id. at 5–6.

[26] Id. at 6.

[27] Id.

[28] Id. at 7.

[29] Id. at 9–10.

[30] Id. at 9.

[31] Id. at 10.

[32] Id.

[33] Id. at 9.

[34] Id. at 10.

[35] Id.

[36] Id. at 15.

[37] Id.

[38] Id.

[39] Id. at 16.

[40] Id.

[41] Id.

[42] Id. at 17.

[43] Id.

[44] Id. at 18.

[45] Id. at 19.

[46] Id.

[47] Id.

[48] Id. at 20.

[49] Id.

[50] Id. at 19.

[51] Id. at 20.

[52] Id. at 21.

[53] Id. at 21.

[54] Id. at 22.

[55] Id. at 23.

[56] Id. at 24.

[57] Id.

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