LawProse Lesson #210: Collective vs. Mass Nouns

LawProse Lesson #210: Collective vs. Mass Nouns

Collective vs. Mass Nouns.      In last week’s lesson on and/or, one of the examples used this sentence: The team of lawyers, paralegals, and mediators resolved the case quickly for their clients. One reader wrote and asked why the correct wording isn’t “its clients” instead of “their clients.” It’s an arguable point—but one with a preponderance of the merits on one side. Team is a collective noun referring to a group of people or things. Grammatically, such nouns are normally singular {group} {flock} {faculty}. But the pronouns and verbs they take can be either singular or plural, depending on whether the emphasis is on the group acting as a unit or on the constituent members acting individually. (We addressed this in greater detail in Lesson #162.) The singular or plural treatment also depends on whether you’re using American English (AmE) or British English (BrE). In BrE, where the preference is to treat collective nouns as plural, no one would bat an eye at “the team are” or “the team . . . their.” In AmE, by contrast, the preference is toward treating collective nouns as singular {The flock begins its migration in Canada.} {The executive board answers to its corporate shareholders.}. The plural treatment often sounds awkward to American ears. So if the emphasis is on the group members acting individually, it is best to add members or a similar noun explicitly referring to the group’s individual constituents, dodging any question about grammatical agreement. Awkward: The committee are debating their decision. Better: The members of the committee are debating their decision. Better still: The committee members are debating their decision. Team, however, is a little more flexible than other collective nouns in AmE. A categorical exception, team names are almost always treated as plural even in AmE. So we’re used to thinking of teams in terms of their members, even when those members are acting as a unit. This may be because team names tend to be plural {Denver Broncos} {Detroit Tigers}—but this remains true even when team names are singular in form {The Tampa Bay Lightning were founded in 1992.} {The Utah Jazz were originally located in New Orleans.}. Names of organizations such as companies or law firms, on the other hand, typically take singular verbs and pronouns, as the reference is usually to the body as a whole—even when the name is plural in form {American Airlines has a fleet of nearly 1,000 aircraft.} {Kirkland & Ellis is representing the plaintiff.}. If verb choice with a collective noun has you stumped, try looking to the pronoun, the choice of which often comes more instinctively. While you could drive yourself mad trying to decide whether the Miami Heat is having a bad season or are having one, you would never say, “It didn’t make the playoffs.” They didn’t. (So they are having a bad season—or were.) Likewise, you’d never say, “US Airways benefited from their merger with American Airlines.” It benefited from its merger with American. Collective nouns shouldn’t be confused with mass nouns, also called “noncount nouns,” which cannot be broken down or individually enumerated. These are generally either abstract nouns {courage} {evidence} {communism} or concrete nouns referring to an aggregation of things taken as an indeterminate whole {luggage} {cutlery} {stationery}. The key difference between mass nouns and collective nouns is that unlike collective nouns, mass nouns never take indefinite articles (a or an) and typically do not have plural forms. (Compare a team to an evidence, or two groups to two luggages.) Some mass nouns, however, are always plural in form {manners} {scissors} {clothes}. But just as singular mass nouns don’t take an indefinite article, plural mass nouns don’t combine with numbers: you’d never say “three scissors” or “six manners.” Some that refer to concrete objects, such as scissors or sunglasses, can be enumerated by adding words such as pair of {a pair of scissors} {three pairs of sunglasses}. Likewise, singular concrete mass nouns can usually be enumerated with words such as piece of {a piece of cutlery} {seven pieces of stationery}. In short, while mass nouns are always treated as singular (except for the always-plural exceptions), collective nouns can go either way, depending on context. There’s little in the way of “right” and “wrong” here: the most important concern is that once you choose singular or plural, you should apply that choice consistently, both between pronouns and verbs and throughout a given piece of writing. Back to the sentence we began with. Should it be “their clients” or “its clients”? As we’ve seen, a perfectly good argument could be made for treating team as singular. But the sentence as written is equally defensible: though the prepositional phrase of lawyers, paralegals, and mediators doesn’t affect grammatical concord (team is still the pronoun’s antecedent), the enumeration of the team’s members militates in favor of a plural sense. The choice is ultimately yours, and neither choice is wrong—as long as you stick with it. Next week, we’ll discuss how nouns of multitude, which are collective or mass nouns denoting quantity, followed by of {a number of} {a bunch of} {the majority of}, are treated differently. Further reading: Garner’s Dictionary of Legal Usage 172–73 (s.v. “collective nouns”), 684 (s.v. “plurals (B)”), 874–75 (s.v. “synesis”) (3d ed. 2011). Garner’s Modern American Usage 164 (s.v. “collective nouns”), 209 (s.v. “count nouns and mass nouns”) (3d ed. 2009). The Redbook: A Manual on Legal Style § 10.10(j), at 181; § 10.25(b), at 195–96 (3d ed. 2013). The Chicago Manual of Style §§ 5.8–5.9, at 205; § 5.31, at 210–11; § 5.131, at 238 (16th ed. 2010). William A. Sabin, The Gregg Reference Manual ¶¶ 1019–1020, at 264–65; ¶ 1049a, at 282 (10th ed. 2005). Longman Grammar of Spoken and Written English § 4.3.2, at 243–45; § 4.3.4, at 247–50 (Douglas Biber et al. eds., 1999). H.W. Fowler, The New Fowler’s Modern English Usage 35 (s.v. “agreement (5)”), 157–58 (s.v. “collective noun”) (R.W. Burchfield ed., 3d ed. 1996). Bill Walsh, Yes, I Could Care Less 76–79 (2013). Thanks to Sam Pietsch for suggesting this topic.

Live seminars this year with Professor Bryan A. Garner: Advanced Legal Writing & Editing

Attend the most popular CLE seminar of all time. More than 215,000 people—including lawyers, judges, law clerks, and paralegals—have benefited since the early 1990s. You'll learn the keys to professional writing and acquire no-nonsense techniques to make your letters, memos, and briefs more powerful.

You'll also learn what doesn't work and why—know-how gathered through Professor Garner's unique experience in training lawyers at the country's top law firms, state and federal courts, government agencies, and Fortune 500 companies.

Professor Garner gives you the keys to make the most of your writing aptitude—in letters, memos, briefs, and more. The seminar covers five essential skills for persuasive writing:

  • framing issues that arrest the readers' attention;
  • cutting wordiness that wastes readers' time;
  • using transitions deftly to make your argument flow;
  • quoting authority more effectively; and
  • tackling your writing projects more efficiently.

He teaches dozens of techniques that make a big difference. Most important, he shows you what doesn't work—and why—and how to cultivate skillfulness.

Register to reserve your spot today.

Have you wanted to bring Professor Garner to teach your group? Contact us at info@lawprose.org for more information about in-house seminars.

Scroll to Top