Followers of trends in appellate practice will have noticed the appearance and rapid growth of the parenthetical “cleaned up” following quoted material in briefs and court opinions. The explanation replaces more cumbersome ones such as “brackets in original; ellipses omitted” and allows a writer to present a cleaner, and hopefully less ambiguous, version of quoted text.
The reference has appeared in the courts of appeal many times over the last few years, but it has now reached the Supreme Court of the United States. Justice Thomas used it in a unanimous opinion released on February 25. See Brownback v. King, No 19-546, slip op. at 6 (2021).
For further background on the parenthetical, its use, and its history, see Professor Volokh’s post on the topic.