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LawProse Lesson: Is e-mails a correct plural, or should it be e-mail messages?

People are naturally drawn to linguistic analogizing: we prefer neat correspondences. Some people therefore insist that because mail is an uncountable mass noun, e-mail must logically be a mass noun as well—and that e-mails is therefore wrong.

These precisians demand e-mail messages.

But to paraphrase Oliver Wendell Holmes Jr. (before he was elevated to the bench), the life of the language has not been logic; it has been experience. Or, as Horace said in about 12 B.C., “Usage is the judge, and law, and rule of speech.”

Here, usage has overwhelmingly dictated that while mail is not a count noun, e-mail can be. You can have 50 e-mails, and you needn’t say e-mail messages. To insist otherwise is to fly in the face of idiomatic English. You wouldn’t say “send a mail to someone,” but most do say “send an e-mail to someone.”

English-speaking peoples value brevity. In the absence of any common term such as e-letter (which denotes instead a newsletter sent by e-mail), speakers have chosen to count their e-mails.

Garner’s Modern American Usage 300 (3d ed. 2009).

Thanks to Martus Granirer, Randy Munyon, and Ty Yankov for suggesting 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 To follow him on Twitter: @bryanagarner.

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