Persnickety Lawyers Hyphenate Phrasal Adjectives

Lawyers who make basic usage and grammar mistakes produce readers who are less receptive to their arguments.

One common usage mistake—and a particular obstinacy of the it’s-right-because-that’s-the-way-I’ve-always-done-it crowd—is failing to hyphenate phrasal adjectives.

Novice readers are usually ignorant of this mistake. But experienced readers get distracted—even downright irritated—when they encounter it.

So what are phrasal adjectives? And why is it important to hyphenate them correctly?

What’s the General Rule?

According to Garner’s Modern American Usage, a phrasal adjective occurs “[w]hen a phrase functions as an adjective preceding the noun it modifies.” Phrasal adjectives are sometimes called adjectival compoundscompound modifiers, or stacked modifiers.

Legal writing is replete with phrasal adjectives like breach-of-contract claims, personal-injury lawyer, subject-matter jurisdiction, civil-rights case, good-faith exceptionattorney-client privilege, and work-product doctrine.

Some usage guides tell writers to decide on a case-by-case basis whether to include hyphens in phrasal adjectives, and suggest including hyphens only where omitting them would cause confusion.

But Wilson Follett explains why writers should adopt a hard-and-fast rule for hyphenating most phrasal adjectives:

The first and by far the greatest help to reading is the compulsory hyphening that makes a single adjective out of two words before a noun: eighteenth-century painting / fleet-footed Achilles / tumbled-down shack / Morse-code noises / single-stick expert. Nothing gives away the incompetent amateur more quickly than the typescript that neglects this mark of punctuation or that employs it where it is not wanted. . . . [The hyphens in phrasal adjectives] warn the reader that he must fuse two ideas before he can perceive how they apply to the subject.

How Do Hyphens Help Readers?

Theodore BernsteinJohn TrimbleR.W. BurchfieldPatricia T. O’Conner, and Bill Walsh also advise following a bright-line rule for hyphenating most phrasal adjectives because, as Garner summarizes, the hyphens make reading faster and easier:

Upon encountering a [hyphenated] phrasal adjective, the reader isn’t misled into thinking momentarily that the modifying phrase is really a noun itself. In other words, the hyphens greatly clarify the meaning.

Grammar Monkeys point out that comical ambiguities can occur when a writer fails to include the necessary hyphen in a phrasal adjective:

  • A stained-glass ceiling is different than a stained glass ceiling.
  • A small-state senator is not the same as a small state senator.
  • A leaky-home builder is not the same as a leaky home builder.
  • An old-furniture dealer isn’t the same as an old furniture dealer.
  • A violent weather conference isn’t the same as a violent-weather conference.

Or consider Bernstein’s examples of small business men and nursing home care. Does the former example refer to small men who happen to be in business, or to men who run small businesses? And does the latter example refer to the care provided by nurses at home or to the care provided in a nursing home?

In both examples, readers must stop, scratch their heads, and then try to divine the writer’s intent from contextual clues. A single hyphen spares them that inconvenience.

Are There Exceptions?

The authorities listed above give more or less the same exceptions to the general rule that most phrasal adjectives need hyphens. Here’s a quick summary of the primary exceptions, with the examples taken from O’Conner’s Woe is I and Garner’s Modern American Usage:

  1. After the Noun. A hyphen isn’t needed if the modifying phrase follows the noun. So although well-trained person and well-worn rule need hyphens, the person was well trained and this rule is well worn don’t.
  2. Adverbs Ending in -ly. If a phrasal adjective begins with an adverb ending in -ly, the convention is to omit the hyphen. So firmly held opinion and wholly owned subsidiary don’t need hyphens because firmly and wholly are adverbs. But if the phrasal adjective begins with an adjective ending in -ly, it needs a hyphen. So curly-haired boy needs a hyphen because curly is an adjective.
  3. Proper Nouns/Foreign Phrases. A hyphen isn’t needed if the modifying phrase is a proper noun. So Supreme Court term and United States territories don’t need hyphens. A foreign phrase that modifies a noun also doesn’t take a hyphen. So there’s no need for a hyphen in habeas corpus petitionin rem jurisdictionprima facie casead hoc committee, and ex post facto law.
  4. The Modifiers Can Modify Alone: A hyphen isn’t needed if each modifying word can separately modify the noun. So sweet young woman and naughty old man don’t need hyphens because both sweet and young and naughty and old can separately modify woman and man, respectively.
  5. Very-Most-Least-Less. Writers can omit the hyphen if one of the modifying words is very, most, least, or less. So, for example, there’s no need for hyphens in very expensive chairleast likely choiceless costly one, or most preposterous hat.

Don’t Like Hyphenating? Rework the Sentence.

If a lawyer doesn’t like the hyphens in phrasal adjectives, there’s an easy solution to the problem: Rework the sentence by putting the modifying words after the noun.

Consider, for example, faculty-curriculum-committee-meeting minutes. As Martha Kollin points out, a writer can eliminate this “adjectival sea serpent” by placing the modifiers after the noun: minutes of the faculty curriculum committee meeting.

In some cases, though, it’s impossible to put the modifying words after the noun. For example, there’s no way to rewrite the snakelike corporate-practice-of-medicine doctrine, except, perhaps, to write the equally cumbersome doctrine of the corporate practice of medicine.

A writer’s choice in cases like this is to include the hyphens or ignore the rule. The better practice, of course, is to follow the rule despite the optics.

Professional Writers Follow These Rules. Novices Don’t.

Professional writers and editors know the rules for hyphenating phrasal adjectives. But as Garner observes, “[f]or some unfathomable reason—perhaps because they are accustomed to slow, dull, heavy reading—lawyers resist these hyphens.”

So keep this column in mind the next time a colleague reviews a brief you’ve drafted and suggests striking the hyphens in phrasal adjectives. It might be time to force the issue. After all, as Follett says, a writer’s life is much too short to perpetuate the bad habits of incompetent amateurs.


  • Lindsey

    “Professional writers and editors know the rules for hyphenating phrasal adjectives….”

    The logic of this part doesn’t work. You’re saying that professional writers and editors know these rules, but you don’t say they use them (because the majority do not). And then you’re criticizing lawyers by saying they know these rules, but don’t use them? How would a lawyer learn this unless they were taught it? Because they’re not learning it from just any book they read–even most of my law textbooks are liberal about its usage. Considering the Oxford comma is optional in (even professional) writing, a lack of hyphenated phrasal adjectives isn’t that big of a deal.

    • Matthew Salzwedel


      (1) See the heading that precedes the sentence that offends you: “Professional Writers Follow These Rules. Novices Don’t.” Also consider Hemingway, Death in the Afternoon: “If a writer of prose knows enough about what he is writing about he may omit things that he knows and the reader, if the writer is writing truly enough, will have a feeling of those things as strongly as though the writer had stated them.”

      I think I was clear in the column about what professionals know and do when it comes to hyphenating phrasal adjectives.

      (2) I give you Garner, Follett, Bernstein, Trimble, Burchfield, O’Conner, and Walsh as authorities for the phrasal-adjective rule. Bernstein was an assistant managing editor of the New York Times; O’Conner was an editor of the New York Times Book Review; Garner is the leading authority on American usage and the editor of Black’s Law Dictionary.

      Is this Lynne Truss?

      “How would a lawyer learn this unless they [sic] were taught it?”

      Lawyers shouldn’t rely on teachers—much less legal-writing instructors—to teach them all the rules. The teachers might be equally uninformed. Sometimes lawyers—and law students—need to do their own work. E.g., Reading This Column.

      “[E]ven most of my law textbooks are liberal about its usage.”

      Law-school casebooks are hardly models of exemplary writing. See Bryan Garner, The Bad Writing in Casebooks, Student Lawyer (Nov. 2012).


      Most legal-writing authorities disagree with you about the Oxford comma and the importance of hyphenating phrasal adjectives. But of course you’re entitled to your opinions.

  • Brent Tharp

    I like the way you collected all of the collective knowledge on hyphens together for this piece—I would even be so bold as to say I like the exceptions portion of it better than the way Garner has it laid out in his book (though his book is quite remarkable in its breadth). For exception 4, you may want to note that it only applies if the meaning does not change as a result. For example, see your Monkeys exceptions: one can say “stained ceiling” or “glass ceiling,” but in each case the meaning is changed from that of “stained glass ceiling,” so the hyphen must be in place to preserve meaning.

    With regard to the other comment, it’s true that editors and publishers have differing views of how liberally to treat hyphen use. As a professional writer and editor, I can tell you that just because a view differs, does not mean that it hasn’t been fully considered. In terms of mechanical editing, the two biggest jobs, and the ones that ensure a continuing flow of work, are comma/hyphen placement and usage. The Oxford (serial) comma is NOT optional in professional editing—it’s required or not, depending on the specific project, but must be consistent throughout that project—nor is the phrasal-adjective hyphen.

  • Grammarian

    How does your use of Minneapolis-based company square with exception 3 above about not hyphenating proper nouns?

    • Sam Glover

      Minneapolis is only one word. The exception applies to nouns made up of more than one word. So St. Louis-based company is correct, not St.-Louis-based company