According to a Brooklyn Law School professor, the number of adverb-dense disputes over how to properly construe a criminal statute has surged since the 1980s, and the criminalization of white-collar and regulatory offenses in the past 30 years has contributed to adverbs’ proliferation in legal circles.
While U.S. Supreme Court Associate Justice Anthony Kennedy tries his best to not use adverbs on the premise that they are a “cop out” and avoiding them “forces you to confront the significance of your word choice,” Justice Antonin Scalia is unapologetic about the “caustic exploitation” of adverbs in his opinions.