Wisconsin Lawyer: Legal Writing: Dispelling Grammar Myths: ‘To Split’ or ‘Not to Split’ the Infinitive:

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    Legal Writing: Dispelling Grammar Myths: ‘To Split’ or ‘Not to Split’ the Infinitive

    Most modern grammar guides give writers permission to split infinitive verbs if doing so enhances clarity, eloquence, or precision in writing.

    Rebecca K. Blemberg

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    Wisconsin LawyerWisconsin Lawyer
    Vol. 81, No. 12, December 2008

    Legal Writing

    Dispelling Grammar Myths: ‘To Split’ or ‘Not to Split’ the Infinitive  

    Most modern grammar guides give writers permission to split infinitive verbs if doing so enhances clarity, eloquence, or precision in writing. 

    by Rebecca K. Blemberg


    A debate about split infinitives has raged for decades. The controversy is whether a writer may insert a word or words between “to” and a verb, splitting the infinitive form. Perhaps the most famous example of a split infinitive comes from Star Trek: “To boldly go where no man has gone before.” Here, “boldly” splits the infinitive verb form “to go.” The phrase “to boldly go” is strong, inspiring, and rhythmical. But is it correct? Another example of a split infinitive is found in this adage: “To really get to know a lawyer, litigate against her.” Here, “really” splits the infinitive verb form “to get.”

    Most modern grammar guides give writers permission to split infinitive verbs.1 For example, Oxford University Press declares, “In standard English, the principle of allowing split infinitives is broadly accepted as both normal and useful.”2 The Gregg Reference Manual states that splitting infinitives is “no longer considered incorrect.”3 Generations of English-speaking people, however, have been taught that splitting infinitives is improper. Historically, grammar guides classified split infinitives as grammatical error. Accordingly, a grammar-savvy lawyer might ask this question: Should I split an infinitive knowing that someone reading my work might think I have made a grammatical error?

    Yes. Writers should split infinitives if doing so enhances clarity, eloquence, or precision in writing. The writer should know why he split the infinitive form, and he should understand that some readers might believe the split construction to be incorrect. If the split infinitive is not the clearest construction for the sentence, however, the writer should abandon the split infinitive gladly, without hesitation, and with the knowledge that he will avoid distracting readers unwilling to embrace split-infinitive construction.

    Rebecca K. 

    Rebecca K. Blemberg, New York Univ. 2000, is an assistant professor of legal writing at Marquette University Law School. Although she hopes she is not too schoolmarmish, she does have immense respect for language purists, and she is not bothered by split- infinitive construction.  

    Until about the mid-19th century, the practice of splitting infinitives was not frowned upon. Many well-respected writers, including Daniel Defoe, John Donne, Benjamin Franklin, Samuel Johnson, and Samuel Pepys, split infinitive verb forms.4 Then, in 1864, Henry Alford published the book, A Plea for the Queen’s English, in which he admonished against separating “to” from the corresponding verb. Several other English grammar guides that came out after Alford’s forbade the split infinitive, and the proscription persisted as the norm until relatively recently.5 Although linguists debate why the rule against split infinitives gained force in the mid-19th century, many grammarians believe that linguists drew inspiration from Latin in their attempts to impose discipline and rules on English.6 In Latin, “to” is inherent in the verb; “to” is not expressed separately. For example, “to be” in English is “esse” in Latin. “To love” in English is “amare” in Latin. Because “to” is inherent in Latin verbs, mid-19th century English-language scholars reasoned that “to” should not be separated from verbs in English, and thus arose the proscription against split infinitives.

    Most grammarians now believe split infinitives are grammatical. Sometimes, in fact, splitting an infinitive form precisely conveys a writer’s meaning. Consider this example: Our research people need to be trained to quickly communicate their findings to sales representatives.7 This example contains split-infinitive construction, “to quickly communicate.” In using the split infinitive, the writer makes clear that “quickly” modifies “communicate.” If the writer moves “quickly” somewhere else in the sentence, the meaning is altered, or the sentence becomes awkward:

    • Our research people need to be trained quickly to communicate their findings to sales representatives. This revised sentence does not contain a split infinitive, but the meaning is ambiguous. “Quickly” seems to modify “trained” instead of “communicate.”
    • Our research people need to be trained to communicate their findings to sales representatives quickly. This sentence does not contain a split infinitive, but the writer loses the emphasis on “quickly” from the original sentence, and the sentence is slightly awkward.

    Also consider the following example, in which the writer uses split-infinitive construction: He decided to gradually release the hostages. Possible revisions change the meaning of the sentence or make it ambiguous:

    • He decided gradually to release the hostages. This revision changes the meaning of the sentence. Here, “gradually” seems to modify “decided,” so the sentence means that “he” made the decision “gradually.”
    • He decided to release the hostages gradually. This revision renders meaning somewhat ambiguous. A reasonable reader could interpret “gradually” to modify “decided” or “release” or even both words. Only the original sentence makes absolutely clear that “gradually” modifies just “release.”

    Yet another example, penned by Wallace Rice in 1937, is as follows: “Try re-writing this: ‘To more than compensate him for his sacrifice is impossible, to less than compensate him would be a crime, to quite compensate him demands equal sacrifice from us.’”8

    Attempted revision of Rice’s example ruins the rhythmic force, just as revisions would ruin the rhythmic force of “to boldly go where no man has gone before” or “To really get to know a lawyer, litigate against her.”

    Writers should use split infinitives when split-infinitive construction most clearly, precisely, or eloquently expresses meaning. At the same time, there is no reason to split infinitive forms if doing so does not enhance meaning. Often, keeping the “to” and the verb next to one another is the most precise, clear, or eloquent way to communicate. For example, the lawyer wanted to use language precisely is precise and clear. Changing word order does not enhance precision, clarity, or eloquence: The lawyer wanted to precisely use language. Because some readers are distracted by split infinitives, when a writer can choose between a clear sentence with a split infinitive and a clear sentence without a split infinitive, the writer should choose the sentence without the split infinitive.

    In 1926, the venerable H.W. Fowler wrote, “No other grammatical issue has so divided English speakers since the split infinitive was declared to be solecism in the nineteenth century.”9 To an extent, English speakers are still divided. The authorities, however, squarely hold it proper to split infinitive forms in the name of clarity and precision. Webster’s Dictionary goes so far as to say, “Traditionalits’, purists’, and other schoolmarmish stylists’ objections notwithstanding, there is nothing wrong with a split-infinitive in English.”10

    As we meticulously proofread our next written product, we should feel confident about using split infinitives when the split infinitive construction enhances sentence clarity, precision, or eloquence. While checking verb forms, however, we should make certain not to overuse adverbs, words that modify verbs that sometimes come between “to” and the verb. Strong, vivid verbs are much more effective than adverbs, but, alas, adverb overload is a topic for another column.


    1“It is exceedingly difficult to find any authority who condemns the split infinitive--Theodore Bernstein, H.W. Fowler, Ernest Gowers, Eric Partridge, Rudolph Flesch, Wilson Follett, Roy H. Coperud, and others too tedious to enumerate here all agree that there is no logical reason not to split an infinitive.” Bill Bryson, The Mother Tongue: English and How It Got that Way 144 (1990).

    2The New Oxford Dictionary of English (1998).

    3William A. Sabine, The Gregg Reference Manual ¶ 1046 (McGraw-Hill Irwin, 10th ed. 2005).

    4Wallace Rice, Usage Counsel: The Split Infinitive, The English Journal, Vol. 26, No. 3, March 1937 at 238.

    5Id. at 238-39.

    6“No plausible rationale has ever been advanced for the rule [proscribing split infinitives], though it may arise from a hazy notion that because the Latin infinitive is a single word, the equivalent English construction must be treated as if it were indivisible.” The American Heritage College Dictionary 1314 (Houghton Mifflin Co., 3d ed. 1997); see also Anne Enquist & Laurel Currie Oates, Just Writing: Grammar, Punctuation, and Style for the Legal Writer 20 (Aspen 2001).

    7This example comes from Sabine, supra note 3, at ¶ 1046.

    8Rice, supra note 4, at 239.

    9Pocket Fowler’s Modern English Usage 547 (Oxford Univ. Press 2002).

    10Webster’s Encyclopedic Unabridged Dictionary of the English Language 1373 (Random House Co. 1989).

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