(emphasis added) vs (emphasis omitted)
You italicized a few words in a quotation to make your point, or the source had italics you do not want. Which note goes after the citation: (emphasis added), (emphasis omitted) or (emphasis in original)? And where exactly does it go?
If your court’s style manual uses different wording, reply below with it.
The team’s answer
Short answer. (emphasis added) means you put the italics there. (emphasis omitted) means the source had italics and you took them out. If you keep the source’s own italics unchanged, no note is needed unless a reader could take them for yours; then (emphasis in original) settles it. The note goes after the citation.
The rules
[Convention] Words you italicize for stress: (emphasis added) after the citation.
[Convention] Words the source italicized that you print in plain type: (emphasis omitted).
[House style] The source’s own italics, kept as they were: no note, except (emphasis in original) where a reader might otherwise credit the stress to you. If one quotation carries both your italics and the source’s, say which are which.
[House style] Notes about your changes come right after the citation and before any (quoting ...) parenthetical, and each quotation they describe gets its own note, Id. citations included.
[Requirement] In federal appellate briefs, text is in roman type, “although italics or boldface may be used for emphasis.” Fed. R. App. P. 32(a)(6).
One Supreme Court opinion, three uses of two notes
In Michigan v. EPA, 576 U.S. 743 (2015):
Added, after a citation (at 753), quoting what a required study had to consider:
“the health and environmental effects of such emissions, technologies which are available to control such emissions, and the costs of such technologies.” § 7412(n)(1)(B) (emphasis added).
Added, with no citation after it (at 752). The Court had named the subsection in its own sentence, so the note stands alone:
Section 7412(n)(1)(A) directs EPA to determine whether “regulation is appropriate and necessary.” (Emphasis added.)
In original (at 770, Kagan, J., dissenting). Quoting the majority, Justice Kagan kept its italics and said so:
“at this stage.” Ante, at 756 (emphasis in original).
For a removed italic, some opinions use another word, (emphasis deleted), the Supreme Court’s among them. The national form is (emphasis omitted).
In your own brief, quoting page 752
Adding stress:
“No regulation is ‘appropriate’ if it does significantly more harm than good.” Michigan v. EPA, 576 U.S. 743, 752 (2015) (emphasis added).
Removing the Court’s stress on “any”:
The Court faulted a reading that “precludes the Agency from considering any type of cost.” Michigan, 576 U.S. at 752 (emphasis omitted).
Common mistakes
Italics added with no note, so the reader thinks the court stressed the words.
(emphasis added) placed inside the quotation marks instead of after the citation.
(emphasis omitted) for italics you kept, or no note for italics you removed.
Dropping the note on a later Id. citation to the same quotation.
Read more
The Quotations chapter (its opening is free to read): https://citationcode.com/book/quotations (opens in a new tab)
The opinions: https://www.govinfo.gov/content/pkg/USREPORTS-576/pdf/USREPORTS-576-743.pdf (opens in a new tab)
Federal Rules of Appellate Procedure (Dec. 1, 2025 print): https://www.govinfo.gov/content/pkg/CPRT-119HPRT61919/pdf/CPRT-119HPRT61919.pdf (opens in a new tab)