Language, Grammar & Style

As an aspiring member of the legal profession, you are expected to be accurate and precise in using legal terminology. Test your level of legal literacy by selecting the most appropriate term among the choices offered in each of these illustrative sentences from motion practice below.

1. The defendant’s motion to dismiss the complaint for failure to state a cause of action in negligence should be ____________, on the ground that the complaint alleges facts that support all of the elements of a negligence claim.

A. dismissed
B. distinguished
C. denied

2. The plaintiff requests that its motion to ____________ a subpoena seeking all of plaintiff’s business records from the past ten years should be granted on the ground that the subpoena is unreasonably broad in scope.

A. squash
B. quash
C. quit

3. Ruling on defendant’s motion to dismiss the complaint for failure to state a claim with sufficient particularity, the court granted the motion to dismiss, with leave to plaintiff to ____________ the complaint.

A. replead
B. replevin
C. replenish

4. Charged with multiple counts of possessing illegal fireworks after police officers seized the fireworks from defendant’s garage, the defendant moved to ____________ this evidence on the ground that the officers did not have a warrant to conduct a search and seizure.

A. suspend
B. suppress
C. surrender

5. The defendant opposed the prosecution’s offer in evidence of defendant’s prior perjury conviction to ____________ defendant’s credibility in a jury trial, on the ground that the prior conviction was similar to the current charge and that the jurors’ awareness of the conviction would prejudice them against the defendant on the basis of her past conduct.

A. impugn
B. indict
C. impeach

1. The defendant’s motion to dismiss the complaint for failure to state a cause of action in negligence should be Denied on the ground that the complaint alleges facts that support all of the elements of a negligence claim. Motions–applications to a court that typically are made in the course of a lawsuit–are granted or denied; complaints or petitions that initiate a lawsuit or proceeding are subject to dismissal.
2. The plaintiff requests that its motion to quash a subpoena seeking all of plaintiff’s business records from the past ten years should be granted on the ground that the subpoena is unreasonably broad in scope. In law, “quash” means to annul or vacate by judicial action.
3. Ruling on defendant’s motion to dismiss the complaint for failure to state a claim with sufficient particularity, the court granted the motion to dismiss, with leave to plaintiff to replead the complaint. This is a motion challenging the adequacy of the pleadings (here, the complaint) to give notice of a claim. The term “replevin” also has a specific legal usage, but it refers to an action to recover goods that have been wrongfully taken or detained from the rightful possessor.
4. Charged with multiple counts of possessing illegal fireworks after police officers seized the fireworks from defendant’s garage, the defendant moved to suppress this evidence on the ground that the officers did not have a warrant to conduct a search and seizure. The term “suppress” is used in the sense of preventing evidence from being introduced on the ground that it has been illegally obtained. In some instances, once an order suppressing evidence has been issued, it is difficult if not impossible to continue the prosecution of a case.
5. The defendant opposed the prosecution’s offer in evidence of the defendant’s prior perjury conviction to impeach defendant’s credibility in a jury trial, on the ground that the prior conviction was similar to the current charge and that the jurors’ awareness of the conviction would prejudice them against the defendant on the basis of her past conduct. As a point of general usage, the terms “impugn” and “impeach” are both used to refer to a challenge to veracity or integrity. In legal usage, “impeach” refers more specifically to any effort to cast doubt on the veracity of evidence. Another legal usage of “impeach”–to charge a public officer before an authorized tribunal with misconduct in office–is related to, but not synonymous with,”indict,” which in law refers to a formal accusation of crime against an individual.

Legal literacy includes the ability to identify accurately the varieties of statements that a court makes in the course of a judicial opinion. The language in which a judicial statement appears may convey important information about the function of the statement within the underlying legal dispute and possibly its relation to other legal sources (when an opinion “follows,” “limits,” or “distinguishes” an earlier opinion). For example, the “holding” in a case, as distinguished from the court’s recitation of a rule or its reasoning, refers to the court’s answer to the issue presented for decision, that is, it refers to the court’s application of the governing legal rule to the particular set of facts before it. In some cases the court states its holding explicitly; in other instances the holding must be inferred from the result in the case coupled with the court’s key reasoning. In either event, the holding is the portion of an opinion that a court or a litigant may cite as precedent in a later case involving a similar issue. The holding should also be distinguished from a court’s “finding” on a factual question in the case.

In the following examples drawn from the report of the decision in Palmore v. Sidoti, 466 U.S. 429 (1984), which is summarized below, select the term that will characterize most accurately and precisely the character and function of the state court’s or the Supreme Court’s statements in this case.

Summary of the case: In Palmore, the U.S. Supreme Court reviewed a state court decision which, in the words of the Court, had “divest[ed] a natural mother of her infant child because of her remarriage to a person of a different race” and awarded custody to the child’s biological father, who had also remarried. 466 U.S. at 430. Although, in the words of the state court, “there is no issue as to either [parent’s] devotion to the child, adequacy of housing facilities, or respectability of the new spouse of either parent,” the court based its custody decision on a determination that, when the child became of “school age and thus more vulnerable to peer pressures, [she would] suffer from the social stigmatization that is sure to come” from living in a household with a stepparent of a different race. Id. at 431. The U.S. Supreme Court reversed the judgment of the state court on the ground that the Equal Protection Clause of the Fourteenth Amendment prohibited a court from basing its holding on the ground of race. Id. at 433. In the words of the Supreme Court, “[i]t would ignore reality to suggest that racial and ethnic prejudices do not exist or that all manifestations of those prejudices have been eliminated. There is a risk that a child living with a stepparent of a different race may be subject to a variety of pressures and stresses not present if the child were living with parents of the same racial or ethnic origin. The question, however, is whether the reality of private biases and the possible injury they might inflict are permissible considerations for removal of an infant child from the custody of its natural mother. We have little difficulty concluding that they are not. (Footnote omitted.) The Constitution cannot control such prejudices but neither can it tolerate them. Private biases may be outside the reach of the law, but the law cannot, directly or indirectly, give them effect.” Id.

For the full text of the Supreme Court decision, click here.

Judicial Language Quiz

1. In Palmore v. Sidoti, the state court __________ that there was no question as to either biological parent’s devotion to the child.

2. The state court __________ that remaining in a racially mixed household would ultimately have a damaging impact on the child.

3. The state court __________ that, where a child’s biological mother had remarried a person of a different race and it was inevitable that the child would suffer social stigma if she remained with her mother in a mixed-race household, the best interests of the child would be served by awarding custody to the child’s biological father.

4. In reversing the state court’s decision in Palmore, the U.S. Supreme Court __________ that where a state court made no effort to place its custody determination on any ground other than the suspected impact of private racial biases, the state court’s ruling violated the Equal Protection Clause of the Fourteenth Amendment.

5. The Supreme Court __________ that the law cannot give effect to private biases.

You’ve likely read about active and passive voice in Richard Wydick, Plain English for Lawyers (Chapter 4). Here is some more information on what these different constructions are and when you should use each of them. Scroll down to the bottom of the page for links to more online resources covering this topic.

What is passive voice?

In a sentence using active voice, the subject of the sentence performs the action expressed in the verb. In a sentence using passive voice, the subject is acted upon. Examples:

• active voice: The police officer arrested the man.
  (The police officer is the subject of the sentence and is performing the action of arresting.)
• passive voice: The man was arrested by the police officer.
  (The man is the subject of the sentence but he is not performing the action of arresting.)

A shortcut to try and identify passive construction in your writing is to look for an extra “be” verb (is, are, was, were) and the word “by”.

• active voice: The police officer arrested the man.
• passive voice: The man was arrested by the police officer. The man was arrested.

Why should I use the active voice?

1. The active voice is more concise. For example:

• active voice: The dog chased the cat. (five words)
• passive voice: The cat was chased by the dog. (seven words)

2. The active voice is often stronger than the passive voice. For example:

• active voice: Judges must explain the reasons behind their decisions.
• passive voice: The reasons behind their decisions must be explained by judges.

3. The passive voice tempts the writer to omit the identity of the actor, thus producing a fuzzy truncated passive like this:

truncated passive: A copy of every Action Letter shall be sent to the Clerk of the Administrative Office for entry and filing, and a memorandum briefly describing the Action Letter shall be distributed to each Commissioner within three days thereafter.

Using passive voice here leaves a lot of questions: Who is supposed to send the copy to the Clerk? Who is supposed to write the memorandum? Who is supposed to distribute the memorandum? We can’t tell, because the writer used the truncated passive to hide the actor.

 

Is there ever a good reason to use passive voice?

Yes. Here are the four most common good reasons:

• 1Sometimes you may not want to name the actor because you want to play down the actor’s role in the event. (For instance, maybe the actor is your client.) Example: When the lights went out, several punches were thrown.
• Sometimes it’s the action that’s important, not who does it. Example: This Act may be cited as the Unlawful Detention Act of 2002.
• Sometimes you may not know who did the acting. Example: During the following six months, the fence wire was cut on nine separate occasions.
• Sometimes you need the passive in order to connect this sentence smoothly with the preceding sentence or sentences. Example: The key question is, therefore, when did the defendant actually receive the summons and complaint? The summons and complaint were not served on the defendant in person until May 18th.

Be Consistent

Whether you are using active or passive voice, be consistent within a sentence.

• He tried to act cool when he slipped in the puddle, but he was still laughed at by the other students. (Uses active voice in the first clause, passive voice in the second clause)
• He tried to act cool when he slipped in the puddle, but the other students still laughed at him. (Uses active voice in both parts of the sentence.)

For More Information

Grammar Girl, “Active Versus Passive Voice,” 2011. Access at http://www.quickanddirtytips.com/education/grammar/active-voice-versus-passive-voice.

Purdue Online Writing Lab (OWL), “Active and Passive Voice,” 2012. Access at http://owl.english.purdue.edu/owl/resource/539/1/.

1. In Palmore v. Sidoti, the state court found that there was no question as to either biological parent’s devotion to the child. Here, the most accurate term would be “found” because it refers to the state court’s determination of a fact, or, more precisely, to the absence of a negative factual finding concerning either parent’s qualifications to be the child’s custodian.
2. The state court reasoned that remaining in a racially mixed household would ultimately have a damaging impact on the child. The most accurate term would be “reasoned” because here the sentence refers to the state court’s rationale for awarding custody to the father, despite the mother’s fitness as a parent.
3. The state court held that, where a child’s biological mother had remarried a person of a different race and it was inevitable that the child would suffer social stigma if she remained with her mother in a mixed-race household, the best interests of the child would be served by awarding custody to the child’s biological father. Here the appropriate term would be “held” because this sentence refers to the state court’s application of a legal standard (best interests) to a set of facts (child’s living in a mixed-race household following biological mother’s marriage to a man of a different race) as it reaches a specific outcome (awards custody to biological father).
4. In reversing the state court’s decision in Palmore, the U.S. Supreme Court held that where a state court made no effort to place its custody determination on any ground other than the suspected impact of private racial biases, the state court’s ruling violated the Equal Protection Clause of the Fourteenth Amendment. The appropriate term would be “held” because the sentence describes the Supreme Court’s application of a legal rule (racial classification is prohibited by the Equal Protection Clause) to the same set of facts as it reaches a specific result (reversing judgment of the state court).
5. The Supreme Court reasoned that the law cannot give effect to private biases. The most appropriate term would be “reasoned” because here the sentence refers to the rationale that the Supreme Court offers in support of its conclusion that a court’s taking account of racial bias would be to effect a racial classification.

Following are some common transitional words and phrases, organized by the types of cues they offer to readers.

This list is provided courtesy of the Southern Illinois University Writing Centers. You can visit their helpful Web site at www.siu.edu/~write.

Cues that lead the reader forward

To show addition:		To show time:
Again	Moreover	At length	Later
And	Nor	Immediately thereafter	Previously
And then	Too	Soon	Formerly
Besides	Next	After a few hours	First, second
Equally important	First, second, etc.	Afterwards	Next, etc.
Finally	Lastly	Finally	And then
Further	Furthermore	Then

Cues that make the reader stop and compare

But	Notwithstanding	Although
Yet	On the other hand	Although this is true
And yet	On the contrary	While this is true
However	After all	Conversely
Still	For all that	Simultaneously
Nevertheless	In contrast	Meanwhile
Nonetheless	At the same time	In the meantime

Cues that develop and summarize

To give examples:	To emphasize:	To repeat:
For instance	Obviously	In brief
For example	In fact	In short
To demonstrate	As a matter of fact	As I have said
To illustrate	Indeed	As I have noted
As an illustration	In any case	In other words
	In any event
	That is

 

To introduce conclusions:	To summarize:
Hence	In brief
Therefore	On the whole
Accordingly	Summing up
Consequently	To conclude
Thus	In conclusion
As a result

Editing Under Time Pressure

If you haven’t set aside enough time to edit your paper carefully, you can take a shortcut (but never skip this phase!).

1. Read the question in the assignment and highlight keywords and instructions.

2. Plan your essay.

• Preferably, do so in a loud voice, by asking questions to yourself
• Write down what you say (main points and points derived from that one)
• Assign paragraphs to your text. Remember: one paragraph=one idea

3. Write your paper and check your outline as you go along.

4. Read the paper nonstop from the beginning to the end at least once.

When you work on different sections separately and then paste them to the general text, there may be problems of connection between those sections that you’ll fail to detect unless you read the whole text.

5. Proofread and edit your paper.

• Are there any spelling errors?
• Are there any words missing from the sentences?
• Are there any words used incorrectly?
• Can you suggest a better word or word form?
• Look at the nouns. Do they have the appropriate singular or plural endings? Is an article needed? Has the appropriate article been used?
• Look at the verbs. Do the verb endings agree (in person -first, second, third-, or in number -singular or plural) with the subjects? Are the verbs in the appropriate tense?
• Look at punctuation. Do you see any problems with commas, periods, semicolons, quotation marks, etc.?
• Are there words that occur repeatedly but unnecessarily in the text?

Run-on sentences are among the most common sentence-level errors. Although many people think of run-ons as sentences that are just “too long,” the problem has little to do with sentence length.

Simply put, run-on sentences are created when two (or more) independent clauses are improperly joined. (An independent clause is a clause that contains a subject and a verb and can stand alone as a complete sentence.)

In a run-on, independent clauses may be run together, with no punctuation or transitional words between them:

The attorney encouraged her client to settle the case out of court the client refused because he wanted to go to trial.

Or they may be insufficiently connected with just a comma (often called a comma splice):

The lawyer handed the judge a memo, it fell on the floor.

 

Once you’ve identified them, run-ons can be easily corrected in several ways:

• Make the run-on two separate sentences. This is often the best choice when the original sentence is very long: The attorney encouraged her client to settle the case out of court. The client refused because he wanted to go to trial.
• Use a semicolon, or a semicolon plus a transitional word, to link the clauses: The lawyer handed the judge a memo; however, it fell on the floor.
• Use a conjunction (and a comma) to join the clauses: The lawyer handed the judge a memo, but it fell on the floor.
• Reword the sentence to turn one of the independent clauses into a dependent clause using a subordinating conjunction: When the lawyer handed the judge a memo, it fell on the floor.
  • Examples of common subordinating conjunctions: when, because, before, after, whereas, while, and unless.

A fragment can be defined as a sentence that does not express a complete thought – most often because it is missing a key element, such as a subject or verb, or begins with a subordinating word.

The following examples are all fragments, for different reasons:

Example 1: The attorney objecting to the line of questioning.

The problem with this so-called sentence is that it’s missing a verb. Although “objecting” looks like a verb, in this case it’s not. Look closely: The phrase “objecting to the line of questioning” is really being used as an adjective to describe “attorney.” Which attorney is being discussed? The one who’s objecting to the line of questioning.

To make this into a complete sentence, you need to add a verb. If you want to relate a simple, straightforward action, try:

The attorney objected to the line of questioning.

If, however, you wanted to say something more about that attorney, you could write:

The attorney objecting to the line of questioning rose to her feet.

Here, the word “rose” functions as a verb, making this a complete sentence.

Example 2: The jurors remained in the hotel for three days. Bickering the whole time.

While the first sentence here is complete, the second is not – it is missing a subject. The second sentence seems to be an afterthought to the first, so you could link them together:

The jurors remained in the hotel for three days, bickering the whole time.

Or you could add a subject to the second sentence to make it complete:

The jurors remained in the hotel for three days. They were bickering the whole time.

Example 3: Unless the witness testifies.

This sentence is really a dependent (or subordinate) clause that can’t stand on its own. If you read it aloud, you’re probably thinking, “Unless the witness testifies – WHAT?” The writer here probably meant to attach this clause to the sentence before or after it. The problem could be corrected either way:

This case will be dismissed unless the witness testifies.

or

Unless the witness testifies, we will surely lose this case.

You can prevent fragments of this sort by making sure that whenever you begin with a subordinating word (such as unless, because, when, if, etc.), you include enough information in the sentence to create a complete thought.

As a general rule, the best way to avoid creating sentence fragments is to ask yourself, when writing a sentence: “Does this sentence, standing on its own, express a complete thought?” If not, check to see what elements are missing.

Subject/verb agreement can seem straightforward for native speakers and others comfortable with English; however, some circumstances can make it difficult to tell whether a subject and verb really do agree.

 

 

 

 

Punctuation is one component of writing that people seldom think about or notice — except when it is wrong. Purdue University’s Online Writing Lab has an excellent section on punctuation of all kinds. It would be a good investment of time to refresh your memory with the explanations and practice exercises found on that site.

Quotation Marks

Quotation marks are required whenever you are giving the exact words spoken or written by another person. In American English, double quotation marks are used for indicating quotations. Single quotation marks indicate a quote within a quote:

• Prof. McArdle said, “The briefs will be due on Tuesday.”
• Loucas said, “Prof. McArdle said, ‘The briefs will be due on Tuesday.’”

(For those of you familiar with British English conventions, this is a change in style.)

The rules for using other punctuation with quotation marks are fairly straightforward. If you are introducing a quote with a phrase such as “He said,” “The record states,” or “As Justice Scalia wrote,” you must use a comma before the quotation marks:

• The defense attorney shouted, “I object to that question!”

If you want to introduce a quote with an independent clause (a phrase that could stand alone as its own sentence), you must use a colon before the quotation marks:

• The defense attorney raised an objection: “That question is not relevant!”

If, however, you are integrating quoted material within your own sentence, you do not need any introductory punctuation:

• Evelyn described her father as a “stubborn old man.”

You must also be careful about the placement of other punctuation marks at the end of quotations. Commas and periods always go inside quotation marks:

• Lou said, “This class is way too noisy.”
• “This class is way too noisy,” said Lou.

Question marks and exclamation points go inside the quotation marks if they are part of the original quotation:

• The security guard asked, “Whose car is this?”

but remain outside the quotation marks if they are part of your own sentence:

• Did the nurse say, “Dr. Adler will be coming soon”?

(In this case, the nurse is not asking the question; the writer of the sentence is.)

Semicolons and colons at the end of a quotation should be placed outside the quotation marks:

• A certain novel begins with the words, “Call me Ishmael”: do you know which novel it is?

Apostrophes

The two main functions of the apostrophe are to form the possessive case of nouns (indicating ownership) and to indicate a missing letter or letters in a contraction.

Possessives

When forming the possessive of a singular subject, ’s is generally needed:

• The student’s locker was filled with textbooks.
• Margie’s bagels are delicious.

If a singular noun ends in s, you should still use ’s to form the possessive:

• Luis’s car is parked on Main Street.
• Her boss’s office is very large.

However, some writers use an apostrophe alone when the noun is long and contains multiple s sounds. This is not incorrect:

• Officer Gonzales’ gun was stolen.

When forming the possessive of plural nouns, you should add only an apostrophe if the noun ends in s:

• The students’ grades were posted on the board.

But the occasional plural nouns that don’t end in s need ‘s to form the possessive:

• The children’s center opens at 9 a.m.

In two unusual cases, ‘s is used to form a plural noun. This occurs when you want the plural form of a single letter or of a word referred to as the word itself, as in the following examples:

• Patrick got straight A’s throughout four years of college.
• This brief contains too many whether’s.

Never use an apostrophe to form the plural of a proper name:

• The Blochs came over for dinner.

Contractions

The apostrophe is also used to replace missing letters in a contraction. For example, in the following sentence:

• The clerk said the office wouldn’t be open on Saturday.

“wouldn’t” is a contraction for “would not” — the apostrophe replaces the missing o.

Similarly, in the sentence:

• We’re tired from studying too much.

“we’re” stands for “we are,” so the apostrophe replaces the missing a.

Your/You’re & Its/It’s

The two instances that cause the most confusion — and the most mistakes — in apostrophe usage are your/you’re and its/it’s.

Remember the contraction rule, and your choice should be clear. “You’re” stands for “you are,” while “your” is the possessive form of “you”:

• “You’re the top student in your class,” said the dean.

Likewise, “it’s” stands for “it is” or “it has,” while “its” is the possessive form of “it”:

• It’s time for the orchestra to begin its rehearsal.

If you are confused about which word to use in a sentence, pause and ask yourself which meaning you want — a contraction or a possessive noun.

Semicolons

A semicolon can be used to connect two independent clauses that are closely linked in meaning:

• The professor began class at exactly 10 o’clock; students who arrived late missed some of the lectures.

In this example, the two clauses could stand alone as separate sentences, but joining them with a semicolon stresses the relationship between them. Using a comma alone to connect these clauses would not be sufficient and would create a run-on sentence.

A semicolon would also be used to connect independent clauses when a transitional word or phrase is used, such as:

• The small airplane had a smooth flight; however, a sudden gust of wind made its landing a little rough.

Commas

Comma placement can dramatically alter the meaning of a sentence. Comma placement determines the grammatical, and therefore logical, structure of the sentence.

When should I use commas?

• Use commas to separate independent clauses when they are joined by coordinating conjunctions: and, but, for, or, nor, yet.
  • Tuparo began his new job, and Burstyn made changes to the personnel policy. (Note that this could have been expressed in two sentences: Tuparo began his new job. Burstyn made changes to the personnel policy.)
• Introductory expressions should be followed by a comma.
  • After leaving Weber and Orange, Tuparo took a job at LSRA.
  • Therefore, he did not make a counteroffer.
• Use commas to separate three or more words, phrases, or clauses written in a series.
  • I bought eggs, milk, and cheese at the store.
  • Yesterday I read a book, took a walk, and wrote a paper.
• Use a pair of commas in the middle of a sentence to set off clauses, phrases, and words that are not essential to the meaning of the sentence.
  • His neighbor, with whom he had had several serious disagreements, removed a section of the fence. (Note that the clause “with whom he had had several serious disagreements” is not essential to the meaning of the sentence. One way to check this is to see if we could rewrite the sentence to make two complete sentences. Example: His neighbor removed a section of the fence. They had had several serious disagreements.)

When should I not use commas?

• Don’t use commas to set off parts of the sentence that are essential to the meaning, such as clauses beginning with “that”.
  • The book that I borrowed from you is excellent.
  • The last person who saw the victim alive claimed to have seen nothing unusual.
• Tip: “Which” is generally used with a comma, “that” without.
  • Mr. O’Malley’s apartment, which is on the seventh floor, is unsuitable for someone with mobility problems. (Non-essential to the meaning)
  • The bill that Ms. Perez received contained several errors. (Essential to the meaning)
• Commas should not separate subjects from their corresponding verbs.
  •  The new chief operating officer, changed the company’s personnel and benefits policies. (incorrect)
• Commas should not separate verbs from their objects.
  •  The new chief operating officer changed, the company’s personnel and benefits policies. (incorrect)
• Commas should not split a double (or compound) predicate.
  •  Tuparo finished his Masters, and got a new job. (incorrect)

When in doubt, use a comma if you think your reader may be confused about the meaning.

Dash or Hyphen

Rule of thumb: dashes separate, hyphens connect. The en dash is approximately the length of the letter N, and the em dash the length of the letter M. The shorter en dash (–) is used to mark ranges and with the meaning “to” in phrases like “New York–New Jersey crossing.” The longer em dash (—) is used to separate extra information or mark a break in a sentence.

• Dashes offer separation but with added drama.
  • : Everyone in the group left the scene—even her brother. (correct)
• Dashes can also be used to set off a clause, parenthetical expression, or list.
  • His neighbor—with whom he had had several serious disagreements-removed a section of the fence. (you could use commas here instead, but dashes change the emphasis)
  • Our clients—Singh, Lafrance, and Ivanoff—have sent us the documents we requested. (you could use commas here but it would be more confusing to the reader)
• Use a hyphen to connect two parts of a compound noun.
  • E.g., U-turn, stand-in, etc.
• A hyphen is used to join two parts of a hyphenated adjective.
  • E.g., once-in-a-lifetime opportunity, state-run clinic. (This often makes the meaning clearer. Consider the possible meaning of the following: working class president, dirty blonde hair, versus working-class president, dirty-blonde hair.)
• Many prefixes are hyphenated, especially if there may be awkwardness or confusion with the spelling.
  • E.g., ex-husband, pre-1968, semi-integrated, non-nuclear. (Some works are acceptable hyphenated and not. Example: pre-war, prewar.)

For More Information

Purdue Owl Writing Lab (OWL), “Brief Overview of Punctuation,” 2012. (link)

Search for your punctuation question at Grammar Girl. (link)

Punctuation with Citation