Hyphenate or Bust? A Truce on Phrasal Adjectives

Written by Ross Guberman on March 14, 2021


In the legal world, debates about hyphenating “summary judgment standard” or “publicly traded company” are as cordial and restrained as arguments over proper fonts, Oxford commas, and spacing after periods.

Let me try to keep the peace with just these three points:

  • When two or more words form a unit that comes before the noun that the words modify, hyphenate those words.

Scalia: “it is the traditional understanding of public-accommodation laws that they provide rights for customers

Kagan: “no other way to prevent hidden-driveway mishaps

Roberts: “a full-time professor

The entire hyphenated unit is known as a “phrasal adjective” or “compound modifier.”

  • But when the term is familiar, not all good writers will hyphenate the unit.

Sotomayor: “the summary-judgment standard

Breyer: “the summary judgment standard

  • You should not hyphenate phrasal adjectives, in fact, when the first word of the series is an adverb ending in -ly

(The rationale: Readers of English know that adverbs can’t modify the noun, so they don’t need our hyphenation help.)

Thomas: “a publicly traded company

Alito: “a wholly owned subsidiary

I hope that this phrasal-adjective guide has made you an entirely confident hyphenator!


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Ross Guberman

Ross Guberman

Ross Guberman is the president of Legal Writing Pro LLC and the founder of BriefCatch LLC. From Alaska and Hawaii to Paris and Hong Kong, Ross has conducted thousands of workshops on three continents for prominent law firms, judges, agencies, corporations, and associations. His workshops are among the highest rated in the world of professional legal education.

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