The University of Chicago Press,
Exercises from LEGAL WRITING IN PLAIN ENGLISH, Bryan A. Garner

§ 9. Use parallel phrasing for parallel ideas.



Revise the following sentences to cure the unparallel phrasing:

  • The court relied heavily on the district court's statement that the would-be intervenors retained the right to appear through counsel, to participate in the fairness hearing, to conduct discovery, and standing to appeal the court's approval or disapproval of the class-action settlement.
  • Tenant will probably not be able to have the lease declared void and unenforceable for vagueness because it contains all the essential elements of a lease: a description of the premises, the amount of rent to be paid, the term of the lease, and identifies the parties.
  • The Younger doctrine also applies to a state civil proceeding that is (1) ongoing, (2) implicates important state interests, and (3) affords an adequate opportunity to raise federal claims.


Revise the following sentences to cure the unparallel phrasing:

  • The essential elements of a fraud claim under New York law are that:
    1. the defendant made a misrepresentation
    2. of a material fact
    3. that was intended to induce reliance by the plaintiff
    4. which was in fact relied upon by the plaintiff
    5. to the plaintiff's detriment.
  • Where there are already allegations of defects in design, manufacturing, and warnings, a claim that the manufacturer should have recalled its 1999 products is redundant, prejudicial, and directed to the wrong institutional forum.
  • Under Georgia law, the elements necessary for the application of equitable estoppel are (1) a false representation or concealment of facts, (2) it must be within the knowledge of the party making the one or concealing the other, (3) the person affected thereby must be ignorant of the truth, (4) the person seeking to influence the conduct of the other must act intentionally for that purpose, and (5) persons complaining must have been induced to act by reason of such conduct of the other.


Rewrite the following paragraph from a loan agreement so that you highlight the parallel phrases. The parenthetical letters--except for "(A)"--have been deleted. Simply reinsert the missing parenthetical letters "(B)" and "(C)" for the phrases that are parallel to the phrase introduced by "(A)." Study the passage first. Once you've decided where the letters should go, set off the listed items separately (see § 34). You might want to edit the sentence, of course. But be careful not to change the meaning.

2.1 No Default or Violation of the Law. The execution and delivery of this Loan Agreement, or the bond indenture, and any other transaction documents by the Authority, will not result in a breach of the terms of, or constitute a default under, (A) any indenture, mortgage, deed of trust, lease, or other instrument to which the Authority is a party or by which it or any of its property is bound or its bylaws or any of the constitutional or statutory rules or regulations applicable to the Authority or its property.

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© 2001, Bryan A. Garner

These exercises appear in Bryan A. Garner's Legal Writing in Plain English: A Text with Exercises, published by The University of Chicago Press and available at bookstores and on the Web at