supports or disagrees with the proposition. For example: Brown v. Board of Education, 347 U.S. 483 (1954) (overruling Plessy v. Ferguson, 163 U.S. 537 (1896)). Phrases not quoting an authority Explanatory parenthetical phrases not directly quoting the authority usually begin with a present participle and should not begin with a capital letter: See generally John Copeland Nagle & J.B. Ruhl, The Law of Biodiversity and Ecosystem Management 227-45 (2002) (detailing the ESA's prohibition on the possession of protected species). When a complete participial phrase is unnecessary in context, a shorter parenthetical may be substituted: Such standards have been adopted to address a variety of environmental problems. See, e.g., H.B. Jacobini, The New International Sanitary Regulations, 46 Am. J. INT'L L. 727, 727-28(1952) (health-related water quality); Robert L. Meyer, Travaux Preparatoires for the UNESCO World Heritage Convention, 2 EARTH L.J. 45, 45-81 (1976)(conservation of protected areas). Phrases quoting an authority If the parenthetical quotes one or more full sentences, it begins with a capital letter and ends with punctuation: See Committee Note to Interim Rule 8001(f) ("Given the short time limit to file the petition with the circuit clerk, subdivision (f)(1) provides that entry of a certification on the docket does not occur until an effective appeal is taken under Rule 8003(a) or (b)."). Insert a space before the opening parenthesis of the explanatory parenthetical. If the parenthetical does not contain a complete sentence, the writer should not place final punctuation (such as a period) inside it. Place a parenthetical included as part of a citation before an explanatory parenthetical: Fed. R. Civ. P. 30(1) (emphasis added) (also indicating that "[a] party may instruct a deponent not to answer ... when necessary to preserve a privilege"). Shorter parenthetical phrases may be used if a complete participial phrase is unnecessary in the context of the citation: The Florida Supreme court recently declared that "where the seller of a home knows facts materially affecting the value of the property which are not readily observable and are not known to the buyer, the seller is under a duty to disclose them to the buyer." Johnson v. Davis, 480 So. 2d 625, 629 (Fla. 1985) (defective roof in three-year-old home). If a source directly quotes or supports an argument (no signal or "see" before a citation), no parenthetical is necessary. Order in a citation If a cited case has subsequent history or other relevant authority,