The Last Word

Apropos Apostrophes (Part 2)

In Part 1 of our consideration of apostrophes, we examined the basic use of apostrophes to form possessives. Marie A. Moore, Apropos Apostrophes (Part 1), 36 Prob. & Prop. 64 (Mar./Apr. 2022). Now, we’ll look at a few variations on apostrophes used to form possessives, their use in contractions, and their common misuse to create plurals (just don’t!).

A Few Possessive Variations

The general rule dictates that writers make a possessive from a proper name and, in most cases, a singular noun that ends in s by adding an apostrophe followed by an s. But some commentators disagree and call for dropping the s, as in Lynn Truss’ book. See Lynn Truss, Eats, Shoots & Leaves 54-57 (2003) (decrying this usage in American newspapers). Professor Garner observes that the 1996 version of the AP Stylebook, like the nuns in my grammar school, recited this rule as to all singular nouns ending in s. Bryan A. Garner, Modern American Usage 644 (3d ed. 2009). By 2002, however, this stylebook advocated the single apostrophe with no following s for words that end in s that are followed by a word that begins with s and singular names ending with s. Id. Professor Garner now lists as common exceptions only (1) “Biblical and Classical names that end with a /zƏs/ or /eez/ sound,” as in an Achilles’ heel, and (2) corporate and other capitalized names, as in General Motors’ and United States’. Id. at 645. Benjamin Dreyer, the copy chief for Random House, disagrees and urges the use of ’s even for classical and biblical names, but then these rules are evolving, so stay tuned. Benjamin Dreyer, Dreyer’s English 38-39 (2019).

Nouns that show joint possession of a single thing or multiple shared things are formed by the addition of ’s only after the last of those nouns, as in Dreyer and Garner’s rule (when both propound the same rule). See Garner, supra, at 646; Dreyer, supra, at 41–42. On the other hand, when the phrase is meant to show individual possession of separate and distinct things, each possessive noun must be followed by the ’s, as in Dreyer’s and Garner’s books (two books, two authors). See Garner, supra, at 646; Dreyer, supra, at 41-42. Yes, you have to think about it each time.

Contractions

Apparently, in classical texts, the apostrophe was used to show the omission of letters. Truss, supra, at 37-38. In Shakespeare’s day, when the apostrophe began appearing in printed English, that was its purpose: “Fie on’t” and “I am too much i’the sun.” Id. at 38 (quoting Hamlet). This is still the case for dialog, y’all—and what are contractions but transcribed normal speech?

Now contractions and their apostrophes are ubiquitous in modern speech and writing, though we lawyers don’t use them often—or at least, we feel that we shouldn’t use them. Avoiding contractions is a fine rule for contract drafting; a provision stating, “Tenant won’t use the Premises for wild parties,” sounds too much like a hope and not enough like a mandate. But even Professor Garner urges lawyers to go ahead and use contractions in our ordinary communications to clients and colleagues. Bryan A. Garner, Modern Legal Usage 217 (2d ed. 1995).

Don’t Use Apostrophes to Create Plurals Unless . . .

Dreyer admonishes: “DO NOT EVER ATTEMPT TO USE AN APOSTROPHE TO PLURALIZE A WORD.” Dreyer, supra, at 36. This is the rule that, when violated, causes grammar nerds to curl their collective lips with particular glee. We are all familiar with the so-called “greengrocer’s apostrophe”: Special price on potato’s. See Truss, supra, at 49-50; Dreyer, supra, at 36. A grammar stickler may take advantage of this special price, but that stickler will certainly sneer at the grocer’s mistake.

Now the exception: Dreyer acknowledges that an apostrophe should be used for pluralization of letters, as in “p’s and q’s.” Id. at 37. Professor Garner agrees but calls for dropping the apostrophe if the letter is italicized: ps and qs. Garner, Modern American Usage, supra, at 639.

Commentators also disagree about the use of an apostrophe for plural abbreviations or acronyms: REAs or REA’s? Dreyer advises omitting the apostrophe. Dreyer, supra, at 37. Professor Garner agrees but permits the use of an apostrophe to pluralize abbreviations with capital letters and periods, as in M.B.A.’s. Garner, Modern American Usage, supra, at 638.

Confused yet? No wonder, since some of the rules have changed over the years. Professor Garner cites the “modern trend toward simplicity.” Id. To honor this trend, in most cases, it seems safest to use ’s to form a singular noun’s possessive, to use an apostrophe with no s to form plural nouns’ possessives, to use apostrophes to show that you’ve omitted letters in contractions, and to avoid apostrophes altogether when creating plurals.

The Last Word Editor: Marie Antoinette Moore, Sher Garner Cahill Richter Klein & Hilbert, L.L.C., 909 Poydras Street, Suite 2800, New Orleans, LA 70112, (504) 2992100.