One thing that has always annoyed me about The Bluebook is that it permits numbers in a page range to be separated by either an en-dash or a hyphen. See The Bluebook: A Uniform System of Citation R. 3.2(a) at 72 (Columbia Law Review Ass’n, et al. eds., 20th ed. 2015). This has persisted over several editions. If the purpose of the system is uniformity, why give people that choice? For me, the optionality in the rule means that when a group of people work on a brief, I need to remember to make and ruthlessly enforce the - vs. – call early, or someone will have to go back at the end and fix any inconsistencies between authors.
FWIW, I’ve always been an en-dash kind of person. That’s what the Chicago Manual of Style advises. Unlike The Bluebook, the Chicago Manual is written by professional writers and editors who can make up their minds.
But after today, I’m not sure that will hold, at least for word-count briefs. It seems that the word counter in Microsoft Word counts two numbers separated by a hyphen as one word, but two numbers separated by a en-dash as two. In a 14,000 word limit brief, see Cal. R. Ct. 8.204(c)(1), with lots of record and case citations, that can easily cost 100 words or more. So if left with a choice between the tedious task of killing 100 words of text in an already well-edited brief and running a find/replace to switch n-dashes to hyphens, the latter could prove pretty tempting.
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