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LawProse Lesson #140: Which is correct – a Cardinals fan or a Cardinals’ fan?

Last week’s lesson about the possessive form of Red Sox ended with this sentence: “We’ll know shortly, but don’t jinx them with poor usage (unless, of course, you’re a Cardinals fan).” Should that have been written as a possessive: a Cardinals’ fan? Preferably not. Here, the proper name Cardinals functions as an adjective (attributively) to describe the fan, not as a possessive.

But how do you decide whether a proper noun is being used attributively or as a possessive? The possessive case has many functions, only one of which is to show ownership. It can also show origin [the witness’s account], description [a summer’s day], duration [two weeks’ notice], or agency (either as doer or recipient) [the asylum-seeker’s relief]. It typically answers the query “Which one?” or “Whose?”

But if you’re using the indefinite article a or an, then the proper noun is almost always descriptive or attributive. If the possessive answers “which one” or “whose,” the attributive answers the query “What kind?”:

a Cardinals win would tie the series
a Cardinals outfielder made the error
a Cardinals rookie

If you’re using the definite article the, the proper noun is usually either descriptive or possessive, but sometimes it can work both ways:

the Cardinals’ chances of winning
Freese is the Cardinals’ third baseman
the Cardinals [or Cardinals’] stadium seats 46,000
who is the Cardinals [or Cardinals’] mascot?

Many stylists prefer the possessive form in the last two examples.

Confusion occurs most often when the proper name ends in -s. You wouldn’t be inclined to write *a Miami Heat’s fan or *a Utah Jazz’s win. Likewise, you’d say a Beatles fan or a Rolling Stones fan, just as you’d say (without the possessive) a Jethro Tull fan or a Grateful Dead fan. So substitute a proper noun that doesn’t end in -s to see which fits best:

a Heat guard (not Heat’s, thus descriptive)
the Heat’s chances of winning (not Heat, thus possessive)
who is the Heat [or Heat’s] mascot? (could go either way)

What if it’s not a proper noun? Do you write girls’ locker room or girls locker room? The preferable form is girls’ locker room. The Chicago Manual of Style “dispenses with the apostrophe only in proper names (often corporate names) that do not use one or where there is clearly no possessive meaning.” The Gregg Reference Manual suggests “substituting an irregular plural like women.” Because you wouldn’t say *the women locker room, the possessive form is required: the women’s locker room (hence the girls’ locker room).

When the name of a publication or a corporate or governmental organization includes words that could be attributive or possessive, follow the user’s practice {Diners Club} {Ladies’ Home Journal}. If it’s not clear, Gregg suggests this rule: “use an apostrophe if the term is a singular possessive noun or an irregular plural noun” {Wrigley’s gum} {Children’s Medical Center}. But we tend not to use an apostrophe if the term is a regular plural {Department of Veterans Affairs}.

Get things right. But realize that none of the mistakes discussed here is a cardinal sin.

Sources:
Garner’s Modern American Usage 646 (3d ed. 2009).
The Chicago Manual of Style § 7.25, at 356-57 (16th ed. 2010).
Bill Walsh, Lapsing into a Comma 72-74 (2000).
The Associated Press Stylebook and Briefing on Media Law 218 (2013).
Allan M. Siegel & William G. Connolly, The New York Times Manual of Style and Usage 265 (1999).
William A. Sabin, The Gregg Reference Manual § 628, at 184, § 640, at 188 (10th ed. 2005).

Thanks to Jeffrey Krieger and Jeffrey S. Morgan for input on this topic.

Bryan A. Garner, President of LawProse Inc., is the most prolific CLE presenter in the U.S., having trained more than 150,000 lawyers and judges. His book — most prominently Black’s Law Dictionary and Garner’s Modern American Usage — have been cited as authority by every state and federal appellate court, including the highest. For more about him, go to www.lawprose.org. To follow him on Twitter: @bryanagarner.

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