phrase, and because no comma was placed after these words, the 100-mile limitation applied only to operations of the plaintiff in New York, and plaintiff could therefore transport goods between in Connecticut, Pennsylvania, and New Jersey without the 100-mile limitation.
This holding occurred despite (1) the unquestioned intent of the I.C.C. to apply the limitation to all points listed, (2) a twenty-year compliance by the previous certificate holder to the limitations, and (3) the plaintiff's knowledge when he purchased the certificate that the limitation applied to all four states. (The dissent decried the "desperate use of a dangerous comma" in the majority decision.)
In another case, during an appendectomy the surgeon removed the patient's reproductive organs. The patient sued, holding that the consent form she had signed was so ambiguous as to be worthless. The form follows below:
* I hereby authorize the physician in charge to administer such treatment and the surgeon to have administered such anesthetics as found necessary to perform this operation which is advisable in the treatment of this patient.
The drafters of the consent form intended the language of the form to modify the word "treatment" so that the patient would be consenting to an "advisable" extension of the operation. But under the doctrine of the last antecedent, the clause beginning with "which" should have directly followed the word "treatment." As the form was worded, however, the patient had consented to the operation, not to the treatment extending it. Rogers v. Lumbermen Casualty Co., 119 So.2d 649 (La. App. 2nd Cir.)
Under both standard grammar and the doctrine of the last antecedent, the placement of a single comma may change meaning. Consider the following sentences:
* Missing after the burglary were two rings, and a bracelet worth $5,000.
* Missing after the burglary were two rings and a bracelet, worth $5,000.
Because of the position of the comma, you understand that the first sentence means that the bracelet alone was worth $5,000, and the second sentence means that all three items taken together were worth $5,000. The comma in the second sentence indicates that the rule requiring modifying words be placed next to the closest antecedent does not apply.
Writers sometimes intentionally violate the rule to create humor. Benjamin Franklin did so in his advice, "Before a man takes a wife he should have a house and a fire to put her in." But unintentional violation of the legal rule may cause harm rather than merriment.
Gertrude Block is Lecturer Emerita at the University of Florida College of Law. Her book ,"Legal Writing Advice: Questions and Answers" (William S. Hein & Co., Inc.) was published in December 2004. Ms. Block is also author of "Effective Legal Writing", 5th Edition (Foundation Press), with an accompanying instructor's manual. She is co-author of the "Judicial Opinion Writing Manual" (published by the American Bar Association, 1991). Send questions to the ISBA Bar News Language Tips, Illinois State Bar Association, Illinois Bar Center, Springfield, IL 62701, or e-mail her at block@law.ufl.edu.
Melissa Bean to keynote 91st Women's Bar dinner
U.S. Rep. Melissa Bean will be keynote speaker for the 91st annual dinner of the Women's Bar Association of Illinois on Thursday, June 2, at the Chicago Hilton Hotel. She will be introduced by Rep. Jan Schakowsky.
Dawn Clark Netsch, professor emeritus of the Northwestern University College of Law and former Illinois comptroller, will receive the Myra Bradwell Award for her contributions toward advancement of women in the profession.
Dawn M. Gonzalez, a partner at Litchfield Cavo, Chicago, will be installed as WBAI president, succeeding Lori G. Levin, executive director of the Illinois Criminal Justice Information Authority.
Chief Justice Mary Ann G. McMorrow will preside at the installation of Gonzalez, and Chief Judge Timothy C. Evans of Cook County Circuit Court will administer the oath to other incoming officers.
They are Vice Presidents Jennifer Sender and Karen Enright, Treasurer Patrice M. Ball-Reed, and secretaries Catherine Casey (financial), Jeanne M. Reynolds (corresponding) and Maria Kuriakos (recording). Ball-Reed and Reynolds are co-chairs of the dinner.
As WBAI president, Gonzalez will focus on the theme of "Women Making History, Shaping the Future": authoring legislation, resolving conflicts, serving the community, raising families. The diversity of women and the bar association will be celebrated during the dinner.
For reservation details, call the WBAI office, (312) 341-8530.
ABOTA - Illinois
Associate Prof. Nancy Marder of the Chicago-Kent College of Law will speak to the Illinois chapter of the American Board of Trial Advocates during a luncheon Monday, May 23, at the Mid-Day Club, Chicago.
Marder, who participated in the recent ABOTA Jury Summit in Law Vegas, is the author of an essay on the integrity of the jury method of dispute resolution. Call President Wendell W. Clancy at (630) 584-7666 for more information.
Advocates Society
The next monthly meeting of the Advocates Center will take place at 7:30 p.m. Thursday, May 26 (instead of Friday night) at the Copernicus Center, Chicago. Call President Maureen Pikarski at (312) 521-7004.
Appellate Lawyers
Appellate Justice Kent Slater, a member of the ISBA Committee on Legislation, will address a 3rd District luncheon of the Appellate Lawyers Association on Thursday, May 26, at the Kankakee Country Club. Call (312) 554-2090.
Asian American Bar
Asian Pacific American Heritage Month will be commemorated Wednesday, May 25, with 10 a.m. courthouse tours and trial observations at the Richard J. Daley Center.
Participating associations are the Asian American, Chinese American, Filipino-American, Indian American and Korean American Bar. Call Milissa Pacelli, (312) 603-1927.
Black Women Lawyers
A panel discussion, "A Career Without Limits: Maximizing Opportunities in the New Millennium," will be presented Thursday, May 19, by the Black Women Lawyers Association of Greater Chicago. Call (312) 554-2088.
President Sharon E. Jones will be moderator of the luncheon program at Maggiano's Restaurant, 111 W. Grand Ave. Speakers are Deborah A. Elam, Katherine Giscombe, Susan R. Lichtenstein and Roderick A. Palmore.
Bohemian Lawyers
Riverside attorney Anthony M. Slawniak will be installed Thursday, May 19, as president of the Bohemian Lawyers Association of Chicago. The 94th annual dinner will take place at the Riverside Golf Club in North Riverside.
Other incoming offices are Kurt J. Kolar and Brian E. Hosticke, vice presidents; Adalbert Vlazny III, treasurer, and Ann Melichar, secretary. Call Dawn at (630) 668-8500.
Central Illinois Women
The Central Illinois Women's Bar Association will hold its third annual judicial reception from 5:30 to 7:30 p.m. Thursday, May 26m at the Pasfield House in Springfield. Call Kelli Hillis, (217) 544-3403.
Chicago Law Libraries
U.S. Supreme Court librarian Judith Gaskell will speak during a luncheon meeting of the Chicago Association of Law Libraries on Thursday, May 26, at Maggiano's Restaurant, 111 W. Grand Ave. Call Michael Wilson, (312) 558-6300.
Decatur Bar
New officers of the Decatur Bar Association will be elected at the annual meeting and golf outing Wednesday, May 25, at the Scovill Golf Course. Call Steven C. Langhoff, (217) 422-2170.
Slated candidates are President James A. Jankowicz, Vice President Heidi R. Balsley, Treasurer William R. Brown and Secretary Jeffry A. Justice.
DuPage County Bar
Keith E. "Chuck" Roberts Jr. will be installed Tuesday, June 7, as president of the DuPage County Bar Association. Supreme Court Justice Robert R. Thomas will be keynote speaker for the annual dinner at the Wyndham Drake Hotel, Oak Brook. Call (630) 653-7779.
DuPage Women Lawyers
Slated candidates for officers of the DuPage Association of Women Lawyers are President Kimberly Davis; Vice Presidents Maria Tolva Mack, Angel Traub and Patricia Magana; Secretary Patricia Rummer and Treasurer Heather Genck.
Government Bar
The Government Bar Association will hold its annual wine and cheese reception Thursday, June 9. Call Erica R. Clinton, (217) 785-2284 for details.
Illinois Trial Lawyers
The 33rd annual convention, golf outing and installation dinner of the Illinois Trial Lawyers Association will take place Friday, June 3, at the Oak Brook Hills Resort. Call (800) 252-8501.
Kane County Bar
Officers will be elected and deceased members memorialized during the annual meeting of the Kane County Bar Association at 11 a.m. Thursday, May 19, in the County Judicial Center ceremonial courtroom, St. Charles. Tributes will be read for John J. Brittain, Kenneth L. Jones, Michael F. O'Brien and Clarence J. Ruddy. A luncheon will follow.
New officers who will be installed Thursday, June 9, during a dinner at Elgin Country Club are President Michael C. Doyen, Vice Presidents Robert J. Britz and Patrick M. Flaherty, and Secretary-Treasurer David E. Camic. Call (630) 762-1915.
Lake County Bar
Waukegan attorney Deborah L. Goldberg will be installed Friday, June 3, as president of the Lake County Bar Association during a dinner at Highland Park Country Club. Call (847) 244-3143.
Other incoming officers are Vice Presidents Robert S. Smith Jr. and Fredric B. Lesser, Treasurer Stuart A. Reid and Secretary Bryan Winter.
Lee/Ogle County Bars
The Lee County and Ogle County Bar Associations plan an outing to Wrigley Field in Chicago for a baseball game between the Cubs and Milwaukee Brewers on Thursday, June 23. The bus will leave at 9:30 a.m. Call David D. Tess, (815) 562-8754.
Peoria County Bar
The Peoria County bar Association will conduct its annual memorial service at 10:30 a.m. Wednesday, May 25, in courtroom 210 of the County Courthouse. Call (309) 674-6049.
Vermilion County Bar
The Vermilion County Bar Association will conduct a memorial service at 10 a.m. Tuesday, May 24, in courtroom 4a in the County Courthouse.
Joanne Moffic-Silver, a 24-year veteran of the Chicago Board Options Exchange legal department, has been promoted to executive vice president from senior vice president. She also will continue as general counsel and corporate secretary.
Todd Sivia of Alton has joined the Edwardsville firm of Byron, Gerber, Petri & Kalb as an associate in municipal representation, real estate law, general business and estate planning.
James Navarre has joined the Chicago personal injury firm of Cogan & McNabola as an associate. A former assistant Cook County state's attorney in felony trials, he has been with Hinshaw & Culbertson.
Allan Sternstein has been added in the Chicago office of Dykema Gossett as a partner in interdisciplinary intellectual property litigation and co-leader of the Intellectual Property Group. A former partner in Brinks, Hofer, Gilson & Lione and patent counsel to Abbott Laboratories, he is an adjunct professor at the University of Illinois.
Christy H. Schaefer is now of counsel to Ellison, Nielsen, Zehe & Antas, Chicago, in insurance litigation. A former partner on Cozen O'Connor, she also was a deputy prosecuting attorney in Marion County, Ind.
Former New Orleans lawyer Reginald Johnson has joined Fox Galvin, St. Louis, to defend employment dispute litigation in Madison and Marion Counties.
Cameron R. Krieger has joined GoodSmith, Gregg & Unruh, Chicago, as an associate. She was with Latham & Watkins.
Alan I. Greene has become a partner in Hinshaw & Culbertson, Chicago. A partner in Michael Best & Friedrich (formerly Schwartz & Freeman) for 15 years, he previously was with Chadwell & Kayser for 20 years.
Scott D. Bjorseth is a new partner in Hoagland, Fitzgerald, Smith & Pranaitis, Alton. Curtis J. Nelson has joined the firm as an associate.
Patricia Levy has joined KMZ Rosenman, Chicago, as special counsel in securities and derivatives law. She was of counsel to The Hull Group, a Goldman Sachs options market company.
Robert S. Strauss has joined Levin Ginsburg, Chicago, as an associate.
Oak Brook attorney E. William Bedrava has closed his private practice and became of counsel to Longwell Associates, which recently celebrated the fifth anniversary of its Oak Brook office.
Daniel A. Kaufman has been named managing partner in the Chicago office of Michael Best & Friedrich. A member of the firm since 1992 and previously managing partner from 1996 to 2000, he practices in its Education Law and Labor and Employment Groups.
David S. Allen has joined Stellato & Schwartz, Chicago, as an associate in appellate practice. He was with McDonald & McCabe.
Partners Jennifer T. Nyman (environmental practice) and Joseph J. Torres (labor and employment practice) of Winston & Strawn, Chicago, have been appointed co-chairs of the firm's diversity committee, now in its third year of developing a diversity charter and implementing a long-term program.
Law firms move, open offices
The real estate law and taxation firm of Elliott & Associates has relocated from Arlington Heights to 1430 Lee St., DesPlaines 60018; telephone (847) 298-8300. Partner Joanne Elliott is a member of the ISBA State and Local Taxation Section Council.
Hinshaw & Culbertson has opened a Madison County office at 156 N. Main St., Edwardsville 62025; telephone (618) 655-0342. Jeffrey Glass is partner in charge of both the Belleville and Edwardsville offices.