Conjunction , Junction , is That Your Function ?
By Jennifer Cook , Denitsa Mavrova Heinrich , and Jenny Samarzja
THE LEGAL WRITING
CORNER
Whether you heard it on " Schoolhouse Rock !" or from your English teacher , you likely remember that a conjunction connects two or more words , phrases , or sentences together . When the words , phrases , or sentences are of equal status , the conjunctions that connect them are called coordinating conjunctions . 1 You may also remember hearing that starting a sentence with a coordinating conjunction ( think FANBOYS ) – for , and , nor , but , or , yet , or so – is poor grammar . But , contrary to this often-held belief , using coordinating conjunctions as sentence-starters is both grammatically proper and rhetorically persuasive .
First , starting a sentence with a coordinating conjunction is grammatically proper . 2 Each coordinating conjunction serves a purpose . And , for example , signals additional support for a proposition . But and yet emphasize contrast . Or suggests an alternative , while so indicates a logical conclusion . Thus , “[ t ] he idea that and must not begin a sentence , or even a paragraph , is an empty superstition . The same goes for but . Indeed , either word can give unimprovably early warning of the sort of thing that is to follow .” 3 Sure , you can substitute coordinating conjunctions for adverbs like additionally , however , or accordingly . Grammatically , these sentencestarters are perfectly fine . But they can weigh down the prose , which takes us to our second point – using coordinating conjunctions as sentence-starters is rhetorically persuasive .
Good legal writers know that everything they write should be speakable . 4 In other words , if you wouldn ’ t say it , then don ’ t write it . 5 We use coordinating conjunctions as sentencestarters in speech all the time . So why not do so in writing ? Using and , but , or so to start a sentence makes the tone of our writing more natural , honest , and conversational . Compare these two examples :
However , the EPA cannot claim that ADEC ’ s decision was “ unreasoned .” Moreover , the EPA also lacks the ability to assert that ADEC ’ s determination in any way results in emissions exceeding national standards or permitted increments . 6
These sentence-starting adverbs , while grammatically proper , sound cumbersome and stiff . Now look at what Chief Justice Roberts wrote instead :
But the EPA cannot claim that ADEC ’ s decision was “ unreasoned .” Nor can the EPA assert that ADEC ’ s determination in any way results in emissions exceeding national standards or permitted increments . 7
By replacing the heavy adverbs with the punchier , one-syllable coordinating conjunctions , Chief Justice Roberts helped the reader move from one sentence to the next with ease and speed . He increased the readability of his writing by making it speakable . And , in turn , he made his prose more memorable .
Here is another example of the rhetorical power of coordinating conjunctions as sentence-starters . Look at this series of sentences from Justice Kagan ’ s recent dissent in Edwards v . Vannoy : 8
For only then is the jury ’ s finding of guilt certain enough – secure enough , mistakeproof enough – to take away the person ’ s freedom ...
And it does so with barely a reason given , much less the “ special justification ” our law demands . . . .
Nor can the majority explain its result by relying on precedent . . . .
But adopting the premise requires departing from judicial practice and principle . . . .
Or as Justice Kavanaugh put the point more concretely , the unanimity rule then helps prevent “ racial prejudice ” from resulting in wrongful convictions .
Yet the Court insists that Ramos ’ s holding does not count as a “ watershed ” procedural rule . . .
So Thedrick Edwards , unlike Evangelisto Ramos , will serve the rest of his life in prison based on a 10-to-2 jury verdict . . . .
There you have it – FANBOYS . By using coordinating conjunctions as sentencestarters , Justice Kagan made her writing style more relaxed , her appeal to the reader more credible , and her prose more persuasive . And so , while some grammar myths are hard to die , the one about not using coordinating conjunctions as sentencestarters need not live to see another day .
1 . BRYAN A . GARNER , THE REDBOOK 212
( 3d ed . 2013 ). 2 . Id . 3 . Id . ( internal quotations omitted ). 4 . See BRYAN A . GARNER , LEGAL WRITING
IN PLAIN ENGLISH 48-49 ( 2001 ). 5 . Id . ( describing the test for naturally sounding writing ). 6 . ROSS GUBERMAN , POINT MADE 175 ( 2011 ). 7 . Id . ( quoting Petitioner ’ s Brief in Alaska v . EPA ,
540 U . S . 461 ( 2004 )). 8 . Edwards v . Vannoy , 593 U . S . ___ ( 2021 )
( Kagan , J ., dissenting ).
Jennifer Cook , Denitsa Mavrova Heinrich , and Jenny Samarzja are faculty members in the Lawyering Skills Program at the University of North Dakota School of Law . This column is the first in their upcoming “ Legal Writing Corner ” series .
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