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“Happy National Grammar Day,” by Joshua T. Katz

Today, March 4, is National Grammar Day: an occasion, the NGD website tells us, to “celebrate good grammar in both our written and spoken communication.” Since I am a linguist and get my quotidian kicks out of thinking about grammar, I am glad NGD exists, though today is also the more serious World Day of the Fight against Sexual Exploitation, as well as Toy Soldier Day, Marching Music Day, Exelauno Day (that’s “March Forth” in Xenophon’s Anabasis—get it?), National Sons Day, National Hug a GI Day, and National Pound Cake Day.

Linguists, who tend to prefer to describe how people use language rather than prescribe how they should do so, often grumble about NGD because, at least at its inception in 2008, it was promoted by language mavens—the sorts of people who prefer prescription to description and who will corner you at a party and explain exactly how removing the first two commas in the present sentence affects its meaning by making a nonrestrictive relative clause restrictive. But for many years now, Mignon Fogarty (“Grammar Girl”) has presided over the website and the holiday, and I am not alone in appreciating her balanced approach between language’s “is” and its “ought.”

How might we best celebrate grammar today? I propose to commemorate the linguistic skills and quirks of two very different men who have significant anniversaries in early 2026: the English lexicographer H. W. Fowler, who published his most famous work in 1926, and the linguistically fastidious American jurist Antonin Scalia, who died in 2016. And I propose in addition to praise one of the greatest living American lexicographers, through whom Fowler and Scalia are linked: Bryan A. Garner, who collaborated on two books with his friend Scalia and whose guide to English usage is the contemporary answer to Fowler’s.

I am both an academic linguist and a largely unrepentant pedant, though not always at the same moment. This combination allows me to care about language in all its forms while also driving me to note that my own sense of style would prefer us to celebrate good grammar by adding another word to Fogarty’s description of NGD: “in both our written and our spoken communication.” Unless, of course, Fogarty means general spoken communication but, when it comes to writing, just ours—which she obviously doesn’t.

On April 22, 1926— one hundred years ago next month—Fowler published A Dictionary of Modern English Usage. This substantial reference work, which Oxford University Press keeps in print in its first edition (a “surpris[ing] . . . decision for which the publisher deserves much credit,” to quote Barton Swaim in these pages) besides promoting Jeremy Butterfield’s considerably revised fourth (“Fowler for the 21st Century”), has probably done more than any other book of its kind to delight and annoy those who think actively about our language. In recent months, writers in as different venues as The New Yorker and the Claremont Review of Books have begun to celebrate the centenary or, if not wholly celebrate, at least give Fowler his due for producing what Garner calls “a category-creating book.”

Fowler’s only competitor for popularity is another book with an April birthday, Strunk and White’s The Elements of Style, first published on April 16, 1959. But Strunk & White, which is much thinner and more American than Fowler, is linguistically poor. (Maira Kalman’s illustrations for the 2005 Penguin Random House edition add verve missing from the familiar little paperback, which to this day remains, unfortunately, Amazon’s “#1 Best Seller in Grammar Reference.”) As the linguist Geoffrey K. Pullum put it in a 2009 article titled “50 Years of Stupid Grammar Advice,” Strunk & White’s “enormous influence has not improved American students’ grasp of English grammar; it has significantly degraded it.” To be sure, Pullum isn’t fond of Fowler either, at least as a guide for the present time, but he does recognize the man’s scholarly virtues amid his eccentricity.

Let’s turn to the law. Last month, many groups marked the tenth anniversary of Antonin Scalia’s passing on February 13, 2016. The American Enterprise Institute, for instance, where Scalia worked in 1977 and with which he was associated for some years, held a two-day symposium on the justice’s legacy, during which most speakers commented on his legendary attention to the niceties of English. The concluding panel, “Antonin Scalia, the Writer,” featured two former Scalia clerks from the 1991 term, Ed Whelan and Judge Jeffrey Sutton, and the justice’s son Christopher, who is both my colleague at AEI and the poetry editor of The New Criterion.

Many symposiasts quoted the justice’s pithy phrases and those jingly words in which he took such pleasure: “This wolf comes as a wolf,” “legalistic argle-bargle,” “jiggery-pokery,” and the like. But, no doubt because it makes for fewer laughs on stage, there were mostly only nods to, rather than substantial direct quotation of, what one might call standard Scalia prose.

Undeniably, one reason that Scalia’s opinions, especially his dissents, are such fun to read is that he had a way with biting words. It seems unlikely that anyone else would have dissented from Obergefell v. Hodges (2015) by writing this footnote about his colleague Justice Anthony Kennedy’s majority opinion, which he described as “couched in a style that is as pretentious as its content is egotistic”:

If, even as the price to be paid for a fifth vote, I ever joined an opinion for the Court that began: “The Constitution promises liberty to all within its reach, a liberty that includes certain specific rights that allow persons, within a lawful realm, to define and express their identity,” I would hide my head in a bag. The Supreme Court of the United States has descended from the disciplined legal reasoning of John Marshall and Joseph Story to the mystical aphorisms of the fortune cookie.

Mordant, yes, but Scalia never underestimated the seriousness of the judge’s task: to explain, clarify, and apply the law. While he certainly enjoyed grammatical arcana for their own sake, he particularly valued the precision, beauty, and rhetorical power that come from carefully composed sober prose. The beginnings of many of his own majority opinions are famously straightforward, drawing in the reader with a quick and vivid setting of the scene. Here are two illustrations: “In the predawn hours of June 21, 1990, petitioner and several other teenagers allegedly assembled a crudely made cross by taping together broken chair legs” (R.A.V. v. City of St. Paul, 1992) and “Petitioner Michael Crawford stabbed a man who allegedly tried to rape his wife, Sylvia” (Crawford v. Washington, 2004). These are not fortune cookies.

Scalia’s most important extracameral linguistic contribution is his 2012 book Reading Law: The Interpretation of Legal Texts, written with Garner, with whom he also published Making Your Case: The Art of Persuading Judges (2008) and who came out with Nino and Me: An Intimate Portrait of Scalia’s Last Years two years after the justice’s death. In their second joint book, the authors make their desire for precision plain while also granting that laws are not always written as they themselves might wish. One example: in a section on punctuation, after noting that “hostility to punctuation exists” and chastising the Vermont Supreme Court for its abuse of the semicolon, they write that “although the better practice is to use the serial comma, courts should not rely much if any on its omission.” And one more example: on the distinction between restrictive and nonrestrictive relative clauses, they admit that “[t]his grammatical convention,” for which they naturally cite Fowler, “is unfortunately a weak basis for deciding statutory meaning,” though they go on to suggest that “legal drafters would be well-advised in the future to heed Fowler’s recommendation for lucidity and ease.”

The successor to Fowler is Garner’s Modern English Usage, also published by Oxford University Press and now in its fifth edition (2022). Thanks to his use of the Google Books Ngram Viewer, Garner is able to bring together in a remarkable and to my mind wholly compelling way his own feelings about how English should best be used—these feelings, like Fowler’s, are often strong—with a massive body of descriptive data about how people actually use the language.

If you care about English grammar in the twenty-first century, two fat books you must own are Garner’s Modern English Usage and The Cambridge Grammar of the English Language (2002), coauthored by Pullum, whom I have already mentioned, and Rodney Huddleston. Still, there is much more to English, and to any other language, than grammar. The point of language is to communicate, and it is wise in all circumstances to know your audience and determine how best to get your point across: how much or little to say, how directly or indirectly to say it, and with what level of formality or humor. There is a reason that Garner, of all people, chose to title his 2018 memoir Nino and Me rather than Nino and I: the nonstandard pronoun suggests intimacy rather than legalism and was, no doubt, considered more likely to sell.

A good sense of standard grammar is essential for the cultivation of style, for it is only thanks to such a sense that anyone has a basis for deciding when to cleave to the standard and when it is appropriate to use different spelling, pronunciation, punctuation, or syntax to achieve some effect. And the best way to cultivate style is to read widely, beginning at a young age: across authors and genres, across states and countries, across decades and centuries. Attend to what works and what doesn’t, and why, and then find your own voice, for which reading aloud everything that you write should help enormously. Scalia, as Whelan stressed at the AEI symposium last month, revised and revised his words until they sang.

My own boyhood reading very much included Fowler: I enjoyed it so much that I sometimes slept with my parents’ copy of the 1965 second edition under my pillow. (Actually.) Some years later, when I began to follow the Supreme Court more closely, I made sure always to read Scalia—who, his son tells me, loved to talk about Fowler and would occasionally leave the dinner table to get his copy of A Dictionary of Modern English Usage from his study and read aloud from it. (Should I perhaps avoid mentioning Scalia’s decision, in his dissent in Lawrence v. Texas (2003), to reject Fowler and use a “fused participle,” which led to some bad-faith press and a New York Times column by William Safire?)

There are things Fowler and Scalia wrote that make me uneasy, or with which I disagree. The same goes for Garner. But all three gentlemen provide models of grammatical and stylistic clarity and grace that I recommend enthusiastically to everyone. Every day, not just on March 4.

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