Do periods and commas go inside the quotation marks?
You quote a few words from an opinion or a rule and your own sentence ends there, or carries on. Does the period or comma go inside the closing quotation mark, even if the source had a different mark there or none? And where do semicolons, colons and question marks go?
Reply below with a sentence you are unsure about (no client facts) and members can weigh in.
The team’s answer
Short answer. In American legal writing, a period or comma that ends a quotation goes inside the closing quotation mark, even when the source had another mark there or nothing at all. Semicolons and colons stay outside it. Question marks and exclamation points move inside only if the quoted words themselves ask or exclaim.
The rules behind it
[Convention] A closing period or comma sits inside the final quotation mark. A free public-domain citation manual says so, and adds that this holds even though that comma or period is yours, not the source's.
[Convention] Semicolons and colons stay outside the mark.
[Convention] For ? and !, ask whose punctuation it is. If the source's words ask the question, the mark sits inside; if the question is yours, it stays outside.
[Convention] The inside rule covers only the mark at the very end. Adding or changing punctuation anywhere else in the quoted words is an alteration, and it gets brackets.
Some state courts' style manuals for their own opinions take the same approach. If your court publishes one, check it.
Practice sentences built on a real rule
Federal Rule of Appellate Procedure 32(a)(6) begins: "A brief must be set in a plain, roman style, although italics or boldface may be used for emphasis."
The rule has a comma after "style," but your sentence ends there, so a period goes inside:
A brief must be set "in a plain, roman style."
The semicolon is yours, so it stays outside:
The same rule says case names "must be italicized or underlined"; it says nothing about signals.
The question is yours, so the question mark stays outside:
Does the rule reach anything besides case names that are "italicized or underlined"?
What the Supreme Court prints
A comma inside both marks. In United States v. Arvizu, 534 U.S. 266, 273 (2002), the Court says an officer needs reasonable suspicion that criminal activity "'may be afoot,'" and goes straight on to a citation clause. The comma is the Court's, and it sits inside both the single and the double closing mark.
A comma where the source had a period. United States v. Moore, 95 U.S. 760 (1878), wrote on page 763 that the officers concerned "are usually able men, and masters of the subject." When Loper Bright Enters. v. Raimondo, 603 U.S. 369, 386 (2024), borrowed those words in the middle of its own sentence, they became "[t]he officers concerned [were] usually able men, and masters of the subject," with a comma inside where Moore had its period.
A question mark outside. On page 230 of Wilkinson v. Garland, 601 U.S. 209 (2024), Justice Alito's dissent ends a question on the words "questions of law," set in quotation marks, and the question mark comes after the closing mark. The question is the Justice's, not part of the words he quoted.
Common mistakes
Moving the period outside because the source had no period there. It goes inside either way.
A semicolon or colon tucked inside the closing mark.
A question mark inside when the question is your own.
Turning a comma in the middle of a quotation into a period without brackets.
What this note does not cover
Block quotations, which take no quotation marks at all, and the order of notes such as (emphasis added) after the citation.
Read more
The Quotations chapter (its opening is free to read): https://citationcode.com/book/quotations (opens in a new tab)
The free Quotations video lesson: https://citationcode.com/lessons/l03-quotations (opens in a new tab)