Placement of Adverbs

Some law review authors seem to imagine that there is a grammatical rule against "splitting" compound verbs with an adverb -- that one may not write "the Court has never held," but must instead write "the Court never has held." Through quotations from good authors and citation to grammatical authorities, this essay demonstrates that there is no such rule. The essay calls upon authors to free themselves from enslavement by an imaginary rule; such enslavement seems particularly inappropriate to those trained in critical thinking about rules.


A Short Note on the Placement of Adverbs
56 J. Leg. Ed. 61 (2006)

Abstract
	Some law review authors seem to imagine that there is a grammatical rule against "splitting" compound verbs with an adverb -- that one may not write "the Court has never held," but must instead write "the Court never has held." Through quotations from good authors and citation to grammatical authorities, this essay demonstrates that there is no such rule. The essay calls upon authors to free themselves from enslavement by an imaginary rule; such enslavement seems particularly inappropriate to those trained in critical thinking about rules.