how to start a fourth paragraph in an essay

105 Best Words To Start A Paragraph

Chris Drew (PhD)

Dr. Chris Drew is the founder of the Helpful Professor. He holds a PhD in education and has published over 20 articles in scholarly journals. He is the former editor of the Journal of Learning Development in Higher Education. [Image Descriptor: Photo of Chris]

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The first words of a paragraph are crucial as they set the tone and inform the reader about the content that follows.

Known as the ‘topic’ sentence, the first sentence of the paragraph should clearly convey the paragraph’s main idea. 

This article presents a comprehensive list of the best words to start a paragraph, be it the first, second, third, or concluding paragraph.

Words to Start an Introduction Paragraph

The words you choose for starting an essay should establish the context, importance, or conflict of your topic.

The purpose of an introduction is to provide the reader with a clear understanding of the topic, its significance, and the structure of the ensuing discussion or argument.

Students often struggle to think of ways to start introductions because they may feel overwhelmed by the need to effectively summarize and contextualize their topic, capture the reader’s interest, and provide a roadmap for the rest of the paper, all while trying to create a strong first impression.

Choose one of these example words to start an introduction to get yourself started:

• The debate surrounding [topic]…
• [Topic] has garnered attention due to…
• Exploring the complexities of [topic]…
• The significance of [topic] lies in…
• Over the past decade, [topic] has…
• The critical question of [topic]…
• As society grapples with [topic]…
• The rapidly evolving landscape of [topic]…
• A closer examination of [topic] reveals…
• The ongoing conversation around [topic]…

Don’t Miss my Article: 33 Words to Avoid in an Essay

Words to Start a Body Paragraph

The purpose of a body paragraph in an essay is to develop and support the main argument, presenting evidence, examples, and analysis that contribute to the overall thesis.

Students may struggle to think of ways to start body paragraphs because they need to find appropriate transition words or phrases that seamlessly connect the paragraphs, while also introducing a new idea or evidence that builds on the previous points.

This can be challenging, as students must carefully balance the need for continuity and logical flow with the introduction of fresh perspectives.

Try some of these paragraph starters if you’re stuck:

• Building upon previous research…
• As [source] suggests, [topic]…
• Analyzing [topic] through [theory]…
• Considering the impact of [policy]…
• Delving deeper into [topic]…
• Drawing from [author]’s findings…
• [Topic] intersects with [related topic]…
• Contrary to popular belief, [topic]…
• The historical context of [topic]…
• Addressing the challenges of [topic]…

Words to Start a Conclusion Paragraph

The conclusion paragraph wraps up your essay and leaves a lasting impression on the reader.

It should convincingly summarize your thesis and main points. For more tips on writing a compelling conclusion, consider the following examples of ways to say “in conclusion”:

• In summary, [topic] demonstrates…
• The evidence overwhelmingly suggests…
• Taking all factors into account…
• In light of the analysis, [topic]…
• Ultimately, [topic] plays a crucial role…
• In light of these findings…
• Weighing the pros and cons of [topic]…
• By synthesizing the key points…
• The interplay of factors in [topic]…
• [Topic] leaves us with important implications…

Complete List of Transition Words

Above, I’ve provided 30 different examples of phrases you can copy and paste to get started on your paragraphs.

Let’s finish strong with a comprehensive list of transition words you can mix and match to start any paragraph you want:

• Secondly, …
• In addition, …
• Furthermore, …
• Moreover, …
• On the other hand, …
• In contrast, …
• Conversely, …
• Despite this, …
• Nevertheless, …
• Although, …
• As a result, …
• Consequently, …
• Therefore, …
• Additionally, …
• Simultaneously, …
• Meanwhile, …
• In comparison, …
• Comparatively, …
• As previously mentioned, …
• For instance, …
• For example, …
• Specifically, …
• In particular, …
• Significantly, …
• Interestingly, …
• Surprisingly, …
• Importantly, …
• According to [source], …
• As [source] states, …
• As [source] suggests, …
• In the context of, …
• In light of, …
• Taking into consideration, …
• Given that, …
• Considering the fact that, …
• Bearing in mind, …
• To illustrate, …
• To demonstrate, …
• To clarify, …
• To put it simply, …
• In other words, …
• To reiterate, …
• As a matter of fact, …
• Undoubtedly, …
• Unquestionably, …
• Without a doubt, …
• It is worth noting that, …
• One could argue that, …
• It is essential to highlight, …
• It is important to emphasize, …
• It is crucial to mention, …
• When examining, …
• In terms of, …
• With regards to, …
• In relation to, …
• As a consequence, …
• As an illustration, …
• As evidence, …
• Based on [source], …
• Building upon, …
• By the same token, …
• In the same vein, …
• In support of this, …
• In line with, …
• To further support, …
• To substantiate, …
• To provide context, …
• To put this into perspective, …

Tip: Use Right-Branching Sentences to Start your Paragraphs

Sentences should have the key information front-loaded. This makes them easier to read. So, start your sentence with the key information!

To understand this, you need to understand two contrasting types of sentences:

• Left-branching sentences , also known as front-loaded sentences, begin with the main subject and verb, followed by modifiers, additional information, or clauses.
• Right-branching sentences , or back-loaded sentences, start with modifiers, introductory phrases, or clauses, leading to the main subject and verb later in the sentence.

In academic writing, left-branching or front-loaded sentences are generally considered easier to read and more authoritative.

This is because they present the core information—the subject and the verb—at the beginning, making it easier for readers to understand the main point of the sentence.

Front-loading also creates a clear and straightforward sentence structure, which is preferred in academic writing for its clarity and conciseness.

Right-branching or back-loaded sentences, with their more complex and sometimes convoluted structure, can be more challenging for readers to follow and may lead to confusion or misinterpretation.

Take these examples where I’ve highlighted the subject of the sentence in bold. Note that in the right-branching sentences, the topic is front-loaded.

• Right Branching: Researchers found a strong correlation between sleep and cognitive function after analyzing the data from various studies.
• Left-Branching: After analyzing the data from various studies, a strong correlation between sleep and cognitive function was found by researchers.
• The novel was filled with vivid imagery and thought-provoking themes , which captivated the audience from the very first chapter.
• Captivating the audience from the very first chapter, the novel was filled with vivid imagery and thought-provoking themes.

The words you choose to start a paragraph are crucial for setting the tone, establishing context, and ensuring a smooth flow throughout your essay.

By carefully selecting the best words for each type of paragraph, you can create a coherent, engaging, and persuasive piece of writing.

• Chris Drew (PhD) https://helpfulprofessor.com/author/chris-drew-phd/ 101 Class Group Name Ideas (for School Students)
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1. The Introduction

2. a strong thesis statement, 3. topic sentence, 4. structuring the body paragraphs, 5. the conclusion, how to write a 4-paragraph essay.

Used at all levels of education, the four paragraph essay offers a basic format that enables writers to present information in a concise manner. A four paragraph essay is an acceptable format for many types of essays, including cause and effect and compare and contrast essays. The four-paragraph essay consists of an introduction, two body paragraphs and a conclusion. Each paragraph in the essay requires specific information in order for readers to follow a logical flow of information.

The four-paragraph essay consists of an introduction, two body paragraphs and a conclusion.

Begin this paragraph with a “hook” that will make readers interested in your essay.

The University of Maryland University College recommends using:

• a surprising statement or statistic,
• personal story
• or rhetorical question.

Avoid the overused and unoriginal dictionary definition opening. After the opener, provide background information on the topic, which should tell readers the purpose of the essay, as well as what they should expect to read.

A thesis statement provides readers with a condensed version of the analysis or argument that you will discuss in the essay. These are typically one or two sentences, and are located at the end of the introduction paragraph.

A strong thesis statement avoids vague language and is specific and argumentative.

• The topic sentence announces the main focus of the paragraph by stating one of the arguments identified in the thesis statement.
• Provide supporting sentences that offer evidence for your claim.
• End the paragraph with your own observation or analysis.

Your body paragraphs should consist of a clear topic sentence, quotes, and explanations of the supporting evidence you have found. This is where you have the chance to prove your thesis to your reader. In order to do this, you must have strong evidence that supports the claim you are trying to make.

• Rephrase your thesis statement in the concluding paragraph, stating how it has been proven throughout the body paragraphs.
• The conclusion should have a summary of the essay’s main arguments and an explanation on how they are connected.
• Lastly, explain why the topic of your essay is important and why it should matter to the readers.
• University of Maryland University College: Introductions; 2010
• Indiana University: Thesis Statement; Jan. 2008
• University of Maryland University College: Conclusion

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Essay Papers Writing Online

Ultimate guide to writing a five paragraph essay.

Are you struggling with writing essays? Do you find yourself lost in a sea of ideas, unable to structure your thoughts cohesively? The five paragraph essay is a tried-and-true method that can guide you through the writing process with ease. By mastering this format, you can unlock the key to successful and organized writing.

In this article, we will break down the five paragraph essay into easy steps that anyone can follow. From crafting a strong thesis statement to effectively supporting your arguments, we will cover all the essential components of a well-written essay. Whether you are a beginner or a seasoned writer, these tips will help you hone your skills and express your ideas clearly.

Step-by-Step Guide to Mastering the Five Paragraph Essay

Writing a successful five paragraph essay can seem like a daunting task, but with the right approach and strategies, it can become much more manageable. Follow these steps to master the art of writing a powerful five paragraph essay:

• Understand the structure: The five paragraph essay consists of an introduction, three body paragraphs, and a conclusion. Each paragraph serves a specific purpose in conveying your message effectively.
• Brainstorm and plan: Before you start writing, take the time to brainstorm ideas and create an outline. This will help you organize your thoughts and ensure that your essay flows smoothly.
• Write the introduction: Start your essay with a strong hook to grab the reader’s attention. Your introduction should also include a thesis statement, which is the main argument of your essay.
• Develop the body paragraphs: Each body paragraph should focus on a single point that supports your thesis. Use evidence, examples, and analysis to strengthen your argument and make your points clear.
• Conclude effectively: In your conclusion, summarize your main points and restate your thesis in a new way. Leave the reader with a thought-provoking statement or a call to action.

By following these steps and practicing regularly, you can become proficient in writing five paragraph essays that are clear, coherent, and impactful. Remember to revise and edit your work for grammar, punctuation, and clarity to ensure that your essay is polished and professional.

Understanding the Structure of a Five Paragraph Essay

When writing a five paragraph essay, it is important to understand the basic structure that makes up this type of essay. The five paragraph essay consists of an introduction, three body paragraphs, and a conclusion.

Introduction: The introduction is the first paragraph of the essay and sets the tone for the rest of the piece. It should include a hook to grab the reader’s attention, a thesis statement that presents the main idea of the essay, and a brief overview of what will be discussed in the body paragraphs.

Body Paragraphs: The body paragraphs make up the core of the essay and each paragraph should focus on a single point that supports the thesis statement. These paragraphs should include a topic sentence that introduces the main idea, supporting details or evidence, and explanations or analysis of how the evidence supports the thesis.

Conclusion: The conclusion is the final paragraph of the essay and it should summarize the main points discussed in the body paragraphs. It should restate the thesis in different words, and provide a closing thought or reflection on the topic.

By understanding the structure of a five paragraph essay, writers can effectively organize their thoughts and present their ideas in a clear and coherent manner.

Choosing a Strong Thesis Statement

One of the most critical elements of a successful five-paragraph essay is a strong thesis statement. Your thesis statement should clearly and concisely present the main argument or point you will be making in your essay. It serves as the foundation for the entire essay, guiding the reader on what to expect and helping you stay focused throughout your writing.

When choosing a thesis statement, it’s important to make sure it is specific, debatable, and relevant to your topic. Avoid vague statements or generalizations, as they will weaken your argument and fail to provide a clear direction for your essay. Instead, choose a thesis statement that is narrow enough to be effectively supported within the confines of a five-paragraph essay, but broad enough to allow for meaningful discussion.

By choosing a strong thesis statement, you set yourself up for a successful essay that is well-organized, coherent, and persuasive. Take the time to carefully craft your thesis statement, as it will serve as the guiding force behind your entire essay.

Developing Supporting Arguments in Body Paragraphs

When crafting the body paragraphs of your five paragraph essay, it is crucial to develop strong and coherent supporting arguments that back up your thesis statement. Each body paragraph should focus on a single supporting argument that contributes to the overall discussion of your topic.

To effectively develop your supporting arguments, consider using a table to organize your ideas. Start by listing your main argument in the left column, and then provide evidence, examples, and analysis in the right column. This structured approach can help you ensure that each supporting argument is fully developed and logically presented.

Additionally, be sure to use transitional phrases to smoothly connect your supporting arguments within and between paragraphs. Words like “furthermore,” “in addition,” and “on the other hand” can help readers follow your train of thought and understand the progression of your ideas.

Remember, the body paragraphs are where you provide the meat of your argument, so take the time to develop each supporting argument thoroughly and clearly. By presenting compelling evidence and analysis, you can effectively persuade your readers and strengthen the overall impact of your essay.

Polishing Your Writing: Editing and Proofreading Tips

Editing and proofreading are crucial steps in the writing process that can make a significant difference in the clarity and effectiveness of your essay. Here are some tips to help you polish your writing:

1. Take a break before editing: After you finish writing your essay, take a break before starting the editing process. This will help you approach your work with fresh eyes and catch mistakes more easily.

2. Read your essay aloud: Reading your essay aloud can help you identify awkward phrasing, grammar errors, and inconsistencies. This technique can also help you evaluate the flow and coherence of your writing.

3. Use a spelling and grammar checker: Utilize spelling and grammar checkers available in word processing software to catch common errors. However, be mindful that these tools may not catch all mistakes, so it’s essential to manually review your essay as well.

4. Check for coherence and organization: Make sure your ideas flow logically and cohesively throughout your essay. Ensure that each paragraph connects smoothly to the next, and that your arguments are supported by relevant evidence.

5. Look for consistency: Check for consistency in your writing style, tone, and formatting. Ensure that you maintain a consistent voice and perspective throughout your essay to keep your argument coherent.

6. Seek feedback from others: Consider asking a peer, teacher, or tutor to review your essay and provide feedback. External perspectives can help you identify blind spots and areas for improvement in your writing.

7. Proofread carefully: Finally, proofread your essay carefully to catch any remaining errors in spelling, grammar, punctuation, and formatting. Pay attention to details and make any necessary revisions before submitting your final draft.

By following these editing and proofreading tips, you can refine your writing and ensure that your essay is polished and ready for submission.

Tips for Successful Writing: Practice and Feedback

Writing is a skill that improves with practice. The more you write, the better you will become. Set aside time each day to practice writing essays, paragraph by paragraph. This consistent practice will help you develop your writing skills and grow more confident in expressing your ideas.

Seek feedback from your teachers, peers, or mentors. Constructive criticism can help you identify areas for improvement and provide valuable insights into your writing. Take their suggestions into consideration and use them to refine your writing style and structure.

• Set writing goals for yourself and track your progress. Whether it’s completing a certain number of essays in a week or improving your introductions, having specific goals will keep you motivated and focused on your writing development.
• Read widely to expand your vocabulary and expose yourself to different writing styles. The more you read, the more you will learn about effective writing techniques and ways to engage your readers.
• Revise and edit your essays carefully. Pay attention to sentence structure, grammar, punctuation, and spelling. A well-polished essay will demonstrate your attention to detail and dedication to producing high-quality work.

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Some experts argue that focusing on individual actions to combat climate change takes the focus away from the collective action required to keep carbon levels from rising. Change will not be effected, say some others, unless individual actions raise the necessary awareness.

While a reader can see the connection between the sentences above, it’s not immediately clear that the second sentence is providing a counterargument to the first. In the example below, key “old information” is repeated in the second sentence to help readers quickly see the connection. This makes the sequence of ideas easier to follow.  

Sentence pair #2: Effective Transition

Some experts argue that focusing on individual actions to combat climate change takes the focus away from the collective action required to keep carbon levels from rising. Other experts argue that individual actions are key to raising the awareness necessary to effect change.

You can use this same technique to create clear transitions between paragraphs. Here’s an example:

Some experts argue that focusing on individual actions to combat climate change takes the focus away from the collective action required to keep carbon levels from rising. Other experts argue that individual actions are key to raising the awareness necessary to effect change. According to Annie Lowery, individual actions are important to making social change because when individuals take action, they can change values, which can lead to more people becoming invested in fighting climate change. She writes, “Researchers believe that these kinds of household-led trends can help avert climate catastrophe, even if government and corporate actions are far more important” (Lowery).

So, what’s an individual household supposed to do?

The repetition of the word “household” in the new paragraph helps readers see the connection between what has come before (a discussion of whether household actions matter) and what is about to come (a proposal for what types of actions households can take to combat climate change).

Sometimes, transitional words can help readers see how ideas are connected. But it’s not enough to just include a “therefore,” “moreover,” “also,” or “in addition.” You should choose these words carefully to show your readers what kind of connection you are making between your ideas.

To decide which transitional word to use, start by identifying the relationship between your ideas. For example, you might be

• making a comparison or showing a contrast Transitional words that compare and contrast include also, in the same way, similarly, in contrast, yet, on the one hand, on the other hand. But before you signal comparison, ask these questions: Do your readers need another example of the same thing? Is there a new nuance in this next point that distinguishes it from the previous example? For those relationships between ideas, you might try this type of transition: While x may appear the same, it actually raises a new question in a slightly different way. 
• expressing agreement or disagreement When you are making an argument, you need to signal to readers where you stand in relation to other scholars and critics. You may agree with another person’s claim, you may want to concede some part of the argument even if you don’t agree with everything, or you may disagree. Transitional words that signal agreement, concession, and disagreement include however, nevertheless, actually, still, despite, admittedly, still, on the contrary, nonetheless .
• showing cause and effect Transitional phrases that show cause and effect include therefore, hence, consequently, thus, so. Before you choose one of these words, make sure that what you are about to illustrate is really a causal link. Novice writers tend to add therefore and hence when they aren’t sure how to transition; you should reserve these words for when they accurately signal the progression of your ideas.
• explaining or elaborating Transitions can signal to readers that you are going to expand on a point that you have just made or explain something further. Transitional words that signal explanation or elaboration include in other words, for example, for instance, in particular, that is, to illustrate, moreover .
• drawing conclusions You can use transitions to signal to readers that you are moving from the body of your argument to your conclusions. Before you use transitional words to signal conclusions, consider whether you can write a stronger conclusion by creating a transition that shows the relationship between your ideas rather than by flagging the paragraph simply as a conclusion. Transitional words that signal a conclusion include in conclusion , as a result, ultimately, overall— but strong conclusions do not necessarily have to include those phrases.

If you’re not sure which transitional words to use—or whether to use one at all—see if you can explain the connection between your paragraphs or sentence either out loud or in the margins of your draft.

For example, if you write a paragraph in which you summarize physician Atul Gawande’s argument about the value of incremental care, and then you move on to a paragraph that challenges those ideas, you might write down something like this next to the first paragraph: “In this paragraph I summarize Gawande’s main claim.” Then, next to the second paragraph, you might write, “In this paragraph I present a challenge to Gawande’s main claim.” Now that you have identified the relationship between those two paragraphs, you can choose the most effective transition between them. Since the second paragraph in this example challenges the ideas in the first, you might begin with something like “but,” or “however,” to signal that shift for your readers.  

• picture_as_pdf Transitions

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How to Structure an Essay

Essay writing is a fundamental skill, a basic task, that is expected of those who choose to pursue their undergraduate and master’s degrees. It constitutes a key requirement for students to complete a given course credit. However, many students and early career researchers find themselves struggling with the challenge of organizing their thoughts into a coherent, engaging structure. This article is especially for those who see essay writing as a daunting task and face problems in presenting their work in an impactful way.  

Table of Contents

• Writing an essay: basic elements and some key principles  
• Essay structure template 
• Chronological structure 
• Problem-methods-solutions structure 
• Compare and contrast structures 
• Frequently asked questions on essay structure 

Read on as we delve into the basic elements of essay writing, outline key principles for organizing information, and cover some foundational features of writing essays.  

Writing an essay: basic elements and some key principles

Essays are written in a flowing and continuous pattern but with a structure of its own. An introduction, body and conclusion are integral to it. The key is to balance the amount and kind of information to be presented in each part. Various disciplines may have their own conventions or guidelines on the information to be provided in the introduction.  

A clear articulation of the context and background of the study is important, as is the definition of key terms and an outline of specific models or theories used. Readers also need to know the significance of the study and its implications for further research. Most importantly, the thesis or the main proposition should be clearly presented.  

The body of the essay is therefore organized into paragraphs that hold the main ideas and arguments and is presented and analyzed in a logical manner. Ideally, each paragraph of the body focuses on one main point or a distinct topic and must be supported by evidence and analysis. The concluding paragraph should bring back to the reader the key arguments, its significance and food for thought. It is best not to re-state all the points of the essay or introduce a new concept here. 

In other words, certain general guidelines help structure the information in the essay. The information must flow logically with the context or the background information presented in the introductory part of the essay. The arguments are built organically where each paragraph in the body of the essay deals with a different point, yet closely linked to the para preceding and following it. Importantly, when writing essays, early career researchers must be careful in ensuring that each piece of information relates to the main thesis and is a building block to the arguments. 

Essay structure template

• Introduction 
• Provide the context and share significance of the study 
• Clearly articulate the thesis statement 
• Body  
• Paragraph 1 consisting of the first main point, followed by supporting evidence and an analysis of the findings. Transitional words and phrases can be used to move to the next main point. 
• There can be as many paragraphs with the above-mentioned elements as there are points and arguments to support your thesis. 
• Conclusion  
• Bring in key ideas and discuss their significance and relevance 
• Call for action 
• References 

Essay structures

The structure of an essay can be determined by the kind of essay that is required.  

Chronological structure

Also known as the cause-and-effect approach, this is a straightforward way to structure an essay. In such essays, events are discussed sequentially, as they occurred from the earliest to the latest. A chronological structure is useful for discussing a series of events or processes such as historical analyses or narratives of events. The introduction should have the topic sentence. The body of the essay should follow a chorological progression with each para discussing a major aspect of that event with supporting evidence. It ends with a summarizing of the results of the events.  

Problem-methods-solutions structure

Where the essay focuses on a specific problem, the problem-methods-solutions structure can be used to organize the essay. This structure is ideal for essays that address complex issues. It starts with presenting the problem, the context, and thesis statement as introduction to the essay. The major part of the discussion which forms the body of the essay focuses on stating the problem and its significance, the author’s approach or methods adopted to address the problem along with its relevance, and accordingly proposing solution(s) to the identified problem. The concluding part offers a recap of the research problem, methods, and proposed solutions, emphasizing their significance and potential impact. 

Compare and contrast structures

This structure of essay writing is ideally used when two or more key subjects require a comparison of ideas, theories, or phenomena. The three crucial elements, introduction, body, and conclusion, remain the same. The introduction presents the context and the thesis statement. The body of the essay seeks to focus on and highlight differences between the subjects, supported by evidence and analysis. The conclusion is used to summarize the key points of comparison and contrast, offering insights into the significance of the analysis.  

Depending on how the subjects will be discussed, the body of the essay can be organized according to the block method or the alternating method. In the block method, one para discusses one subject and the next para the other subject. In the alternative method, both subjects are discussed in one para based on a particular topic or issue followed by the next para on another issue and so on.  

Frequently asked questions on essay structure

An essay structure serves as a framework for presenting ideas coherently and logically. It comprises three crucial elements: an introduction that communicates the context, topic, and thesis statement; the body focusing on the main points and arguments supported with appropriate evidence followed by its analysis; and a conclusion that ties together the main points and its importance .  

An essay structure well-defined essay structure enhances clarity, coherence, and readability, and is crucial for organizing ideas and arguments to effectively communicate key aspects of a chosen topic. It allows readers to better understand arguments presented and demonstrates the author’s ability to organize and present information systematically. 

Yes, while expert recommend following an essay structure, early career researchers may choose how best to adapt standard essay structures to communicate and share their research in an impactful and engaging way. However, do keep in mind that deviating too far from established structures can hinder comprehension and weaken the overall effectiveness of the essay,  By understanding the basic elements of essay writing and employing appropriate structures such as chronological, problem-methods-solutions, or compare and contrast, researchers can effectively organize their ideas and communicate their findings with clarity and precision. 

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How to write a 4 paragraph essay.

"How to Write a 4-Paragraph Essay" underscores the importance of well-structured paragraphs and topic sentences in effective writing. Addressing the question, "What does a paragraph look like?" a paragraph is defined as a coherent series of sentences, all centered around a single topic. These organized units of writing play a crucial role in guiding the reader through the subdivisions of an essay, helping them discern the essay's organization and comprehend its key points. Paragraphs can encompass diverse information, such as examples, illustrations, descriptions of places, characters, processes, narration of events, comparisons, contrasts, classifications, or discussions on causes and effects.

Despite the variety of content paragraphs can contain, they all share common characteristics, with one of the most crucial being the presence of a topic sentence. This sentence acts as the anchor, encapsulating the main idea of the paragraph and providing readers with a clear understanding of the upcoming content. In essence, paragraphs serve as building blocks in crafting well-organized and coherent essays, ensuring a seamless flow of information for the reader.

Essay Structure - A 4-Paragraph Sample

A 4 paragraph essay may take any form. It could be an argumentative essay, compare and contrast essays, review essays, and so much more. Most four paragraphed essays usually review essays. However, some may be just requiring you to give your point of view on a matter. Therefore, you need to learn how to write this kind of essay. This article will equip you with the basic skills you need to learn to write a great 4 paragraph essay. The most important thing you need to know is how to structure an essay.

The structure of a four paragraph essay is very important as it demonstrates well-thought ideas. In general, these essays take the same structure as any other essay. A well-structured essay has an introduction, a body, and a conclusion. The introduction gives information on the background of the topic and introduces the thesis of the essay. The introduction is followed by the body.

It should be noted that there should be a proper transition between the introduction and the body. The body of the essay contains well thought and explained ideas to support the thesis effectively. For a four-paragraph essay, the introduction should take up one paragraph. The body should be two paragraphs. Finally, the conclusion should tie all the points with the thesis, hence giving the reader a satisfactory answer to the initial question.

We do understand just how daunting a task is writing those four paragraph essays for undergraduate and postgraduate could be - the sleepless nights of trying to find the right words, the anxiety of not having enough words or not knowing what to cut down, the fear of "What if my essay is not good enough?" We can relate to all those feelings. The exciting thing is that the entire team at our custom writing service doesn't find essay writing daunting, and it would be our absolute delight to help you with your essays.

Components of a five-paragraph essay

A proper essay has three main components. They are the introduction, body, and conclusion.

The introduction of an essay is different from that of a research paper. For a research paper, the introduction contains background information on the subject you are to cover on the body. It also includes the thesis statement of the paper. For the case of an essay, the introduction does not give any background information; instead, it is supposed to be brief and captivating. The introduction of an essay should compel the reader to read on. When writing the introduction, do not state the obvious, for example, "this essay is about" or "the essay's topic is." Instead, begin with statements that will grab the attention of the reader, for example, a quote, dialogue, a story, or even an informative statement.

The body consists of your main argument. This is, however, dependent on the purpose of your essay. However, make sure that the transition from the introduction to the body is smooth. At his point, you aim to convince and explain to the reader about your topic. To do this, you will need to have a list of points you want to discuss. Therefore, the body should consist of these points with a detailed explanation. To form a solid argument, you should start with the strongest points, followed by the least strong. Major points should be in separate paragraphs. It is essential to ensure that you have relevant and correct examples to support your points. This will play well for you when persuading the reader.

The conclusion of an essay brings closure to the topic and summarizes the main ideas of the essay. Remind the reader of your thesis statement and show some comments to back it up. You could also suggest ways to solving a particular problem if your essay topic was based on such a topic.

How to write better essays

1. Come up with a topic and a title

The main thing is to come up with an effective topic and a title. Firstly, you must understand the functions of a title which include: prediction of content, catching the reader's attention, it reflects the tone as far as the writing is concerned, and finally, it does contain keywords that are easily searchable

A good title takes time to develop since if you fail to come up with a proper title, then everything will fall as you proceed to establish your essay and you will realize you're losing track in your writing.

2. Choose the principal idea, or thesis, of your essay.

A thesis for an essay is quite important and plays a vital role as well since it ensures that the reader has an idea regarding the essay and the discussions that as concerned with the essay. A thesis statement will bring forth the ideas of the essays direct to the reader, and that is why a thesis statement should be strong and to the point. It shouldn't be complicated and always remember that coming up with a well-stated thesis statement does ensure that the topic is effective and this grasps the attention of the reader. A thesis statement determines the destiny of your essay, and it does portray the effort put in by the writer in coming up with the topic and the resulting outline of the essay.

3. Outline your essay into introductory, body and summary paragraphs:

Introductory Paragraph

• Hook : Most people think that writing is something that only those with a born talent can ever do well.

• Thesis : Proper writing takes practice

• Links to the main ideas to be developed in the essay: Relentless practice and not giving up gives rise to the art of writing.

1st Body Paragraph

• Main idea: Practice leads to proper writing skills

• Support : Writing without prior practice and experience + example

• The Conclusion

2nd Body Paragraph

• Main idea: Prior writing experience has changed how writers bring forth their ideas in writing.

• Support : Prior writing experience enables writers to be more experienced and therefore becoming more creative and at the same time avoiding spelling mistakes and other grammatical errors

• Support : Writing what you have experienced makes it easy to come up with different topics, and as a writer, you are comfortable to write literary about anything that comes your way.

3rd Body Paragraph

• Main idea: Writing experience has changed how writers spend their time writing.

• Support : Writers with the least experience tend to take more time coming up with a specific material, and this might affect the rate at which they develop specific content material or a specific type of writing which they have been assigned.

• Support : Proper writing experience ensures that a writer can write more articles and without anything being compromised for example the quality and the degree of creativeness.

The Concluding Paragraph

• Review of main ideas of each paragraph

• Restatement of thesis: Proper writing takes practice

• Concluding thought: Writing will continue to demand practice and self-motivation.

How to improve writing skills in English for students

1. You need to start on a high note by using a question and most specifically a rhetoric one. This is within the introductory paragraph and the interesting sentence is defined as the hook which tends to capture the attention of the reader.

2. Next you have to come up with the thesis statement. This is everything when it comes to shaping the destiny of your essay.

3. Proceed to introduce the body paragraphs which you will link straight from the introduction. This ensures that the whole essay is connected

4. As you proceed with the body paragraphs, ensure that the main point is stated in the start of the body paragraphs. Ensure you have used examples as illustrations to support the main idea in each paragraph

5. Introduce the summary paragraph which only restates the central ideas of the body paragraphs

6. The last sentence generally restates the thesis of the essay which as discussed earlier on, builds the foundation of the entire essay.

7. The final statement: This can predict anything discussed and backed up in the essay body paragraphs with proper illustrations. At this stage, avoid introducing any new ideas.

How to write a good essay in English quickly in 6 steps

1. Go through the instructions

Before getting to the researching step, ensure to read the instructions first where they are provided. You could come up with the best essay but end up scoring a low grade or end up having your essay rejected as a result of not adhering to specified instructions. Ensure that you stick to the word limit, writing style, or any other guidelines which might be provided. Also, make sure that you submit your essay within the specified time to avoid penalties.

2. Research your topic

The next step is to understand your topic. The topic will either be provided, or you'll have the freedom to choose it yourself. If the topic is provided, this simplifies the option of searching for a topic. However, if it is not offered, the task of coming up with a topic that you can build on is upon you. This could work to your advantage. You could work on choosing a topic that you know is interesting to you. Regardless of the circumstances, it is crucial to conduct critical research on whichever topic you have at hand.

A visit to the library and the internet will usually provide all the information you need to write the essay. Ensure that you use credible sources in your research analysis. Take short notes to use later and arrange them properly to help make your work easier. This is important since you might not be able to remember everything you read from all your sources.

3. Prepare an outline for your essay

By taking a look at the notes you have made, you will find that you already have an idea of how your essay will be structured. You can use the points as a guiding factor to help you arrange your thoughts and make an outline of the essay. For example, at the top of a page, write your topic, and list down the main points. Leave a gap between each point. You can list the other minor points which are related to the main points in the gaps you previously left behind.

This is also a way for you to come up with a rough draft of your essay. The rough draft is the right way for you to find out whether your ideas fully work together; if you find that they do, you can move on to the next step.

4. Come up with a thesis statement

Having chosen your topic and using your outlined and drafted points, you can come up with your thesis statement. This helps the reader understand what the whole point of your essay is. Your main points are the indicators of your essay's theme. They will act as a guide to the reader to help them understand where you're going with your essay and why.

5. Write your essay

Now that you have everything you need, it is time to write your essay. Do not get hung up on details like finding the perfect vocabulary; instead, focus on writing your essay. Having written an outline and possibly a draft writing the essay should not be an issue.

6. Proofread and Edit

Once you're done with your essay, please go through it from the beginning and check that all the words flow together effortlessly. Check that the main objectives of your essay have been fulfilled and that your essay has answered the main issue that was being addressed. An important step is also to check that you have adhered to the rules that were provided at the beginning of your essay. If not, you'll have to correct them.

The next step is to edit any grammatical or typographical errors that might be present. Go through the essay several times to ensure that all available mistakes are corrected and that everything is where it should be.

Sometimes the best thing you can do for your writing is get started early. It may be difficult at first, but an early start can make a world of difference to that essay for class. If you need help, why not buy cheap essays on our service in an easy, fast, and secure way that will never sacrifice your privacy for convenience -it's never worth it.

How to structure 4 paragraph Academic book reviews.

While there are many reasons to write an academic 4 paragraph book review, getting a "publication" is not one of them. Academic 4 paragraph book reviews rank somewhere below publishing in a semi-obscure conference proceedings, and somewhere slightly above "vaguely laudatory service to the profession.”

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Writing a 4 paragraph book review: nine top tips and things to avoid

• Look at past 4 paragraph book reviews they've published about similar books. After you've read the book, look at reviews for the same book from other major sources. Think about who reads the publication and what they most want out of a 4 paragraph book review. Read a bunch of 4 paragraph book reviews, especially from the journal that's asking you. Then you can get a sense for what is typically included in reviews in general, and in ones that you find helpful. Do not to be overly-effusive with praise. You want to be critical.

• E.g., if it's mostly teaching faculty reading this journal/site, they will want a review to address: can this be used in the classroom? Could students read it?

• There's bound to be something about it you like, so talk about that. Use lots of adjectives. It doesn't have to be lengthy and doesn't spoil the plot.

• Again the point here is not “if you can’t say something nice, don’t say it.” The point is writing this kind of essay requires you engage with the arguments the author presents, and don’t just slam them. An academic 4 paragraph book review is not a yelp review.

• Be keen to avoid typos and errata

• Don’t write an academic review of a book that you can't find anything redeemable about.

A 4 paragraph book review is an essential evaluation of a written text or an object, and this covers all the aspects of books, literature material, among many other forms that can be intertwined at this level. Things you should know about a 4 paragraph book review include:

• A review provides the reader with a concise summary of the entire content. This contains descriptions that are based on the topic and also its general argument and perspective or even purpose.

• A review does offer an essential assessment of the written material. It points out what you, as the reader, you find to be worth noting, whether it is captivating, persuasive, and how it made you feel about the whole issue.

• A review overly suggests at the end of the material at hand can be appreciated by an audience. 

How to write a 4 paragraph book review that is due in ...

1.    First, read the book, and as you are reading, make a few notes about the points you want to get across, and these can be in the form of questions:

• What are the author’s purposes and views regarding this book? - This can clearly be stated in such a few words in the preface of the book or the introduction part.

• What form of evidence does the author use to fortify the points he or she has made? Ask yourself if the evidence is compelling- Do points fully get supported by what the author brings forward as hard evidence?

• How does the book correspond to other books with the same topic relate? - Does this book have some unique aspects? Does it add original and new information, and what group of readers will find this book to provide utility? 

• Has the book been written by a professional writer? Does the author have the skills needed to write readable material?

• Which is an ideal level by which the book can criticize the book? Did the author manage to be successful in relaying his ideas across to the reader and achieve the main purpose of writing the book?

2.    Try to imagine you are telling your friend a story regarding something which may be interesting or not. When you do this, then it becomes much easier since you do not have to follow so many rules, which indeed lead to confusion, and then you’re caught in between the writer’s block since you are afraid of doing the wrong thing. A 4 paragraph book review is simple, and you shouldn’t over think it. Just write as if you are telling your friend a book you read last night.

3.    It is indeed imperative as you are telling your friend about the book you read that you do not forget to mention the name of the author. Remember, the story is not yours, and you should give credit where it’s due. It does not take much effort; just a second or two, and you have grasped that point as your professor is grading your paper.

4.    Make specific points regarding what you are planning to write. This makes it a lot easier, and I do it all the time. Make seven points (an example), then per every point, write a paragraph. It’s clear to see that this is the simplest method since you only need to write like 100 words per every point, and you are good to go. That’s an entire paper you’ve just written. Just make sure you list the points before you get to start writing your 4 paragraph book review.

5.    Before beginning to write your 4 paragraph book review, make sure you have made clear what your theme is since it’s quite disappointing if the reader of your 4 paragraph book review reads the entire text, and he or she doesn’t support what you have just reviewed. Make it clear at the beginning what you will be discussing about, and this makes it easier for everyone who is trying to read your 4 paragraph book review.

6.    You also have to grade the book as per its genre. Does it have one in the first place? Like, does it fall under drama, action & adventure, horror, satire, or even mystery? If it does, then state its genre. You have some points there from your professor!

7.    Think about the writing style the author has used. Does it appeal to your sense of humor? What do you like most about the narrative writing used, the descriptive or expository style used by the author. Comment on this the best way to like.

8.    Use quotes from the book itself. I mean, quotes from the author. This will give the reader some sense of authority that you indeed have read the book, and even if you are not agreeing or you agree with the author, it’s right to pass authorization to the author. Use parenthesis (and include page numbers), avoid self-citations; do not make your views on the topic since this is not your written work.

On the issue of self-citation:

• It would be reasonable to avoid repeating what is essential in the author’s work, but you would rather try a dialogue with other authors!

• At the early stage of 4 paragraph book reviewing, we tend to self-cite to boost overall citations. Avoid this pitfall. You will feel embarrassed at a later stage of career to see your papers filled with self-citations.

9.    I have stated this on point number 8, but I want to give you more details regarding the fact that you should not tell readers of your review what the book is about. Those are your views regarding the book, and they are STRICTLY not allowed since it’s not a written invitation to present your opinions regarding the book or the author. Your review should tell the readers if they should read the book, what is good about the book, or why they should not waste time reading the book altogether.

10.    Spend some time and do some light research regarding the author of the book. This information is vital since you will understand more why the author came up with such a book. A book comes from a writer’s mind, and it’s entirely appropriate that when you write a book, it will rotate around your life, your friends, early school life, etc. so a book is just an invitation to the mind of the author, and you have to explore effectively to come up with a well-written 4 paragraph book review.

Just a recap:

• Read the book and makes notes

• Write a 4 paragraph book review just like you’d imagine telling your friend a story

• State the author's name

• Plan your writing by making points

• State the theme of the 4 paragraph book review to readers during the early stages

• State the genre of the book

• State your opinion regarding the writing style used

• Quote the author in your text

• Do not write your ideas for the book. 

• Please do a deep dive and research EVERYTHING.

How to develop a 4 paragraph Book Report.

Instructors do like to assign 4 paragraph book report assignments, whether oral or in written format to 4th graders, and have you ever wondered why? Yes, you could think it’s an intentional way of forcing students to go deep into their books and read a large volume of books in the library. For sure, it’s even more than that if I can tell you the truth. Your instructor intends to broaden your understanding of today’s world and society, and that is precisely what good books do, they enlighten you to think and act the way the current trends in society expect you to behave regarding certain things. Books help in eye-opening and also in critical thinking. They aid in decision making, crucial eye-opening occurrences regarding experiences, and dealing with people too. This proves that a book is a tool that fully demonstrated that you have experienced reading books. 

What does a 4 paragraph book report include? - Depending on your grade level, 4 paragraph book report content may vary. A middle-grade 4 paragraph book report does provide the minimal or let’s say basic details as far as a book is concerned; for example, a plot summary, several comments regarding the scholar’s opinion, and general impressions. With 4 paragraph book reports that concern students on a higher educational level, you expect them to be a little more detailed and even to deal with themes and other complicated things that regard 4 paragraph book reports.

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Useful tips to help you write an outstanding 4 paragraph book report.

Before going too far with the body of your 4 paragraph book report, spend a few minutes to have all the following questions asked and answered at a personal level.

1)    Did you find the book to be enjoyable? - You can opt to answer this question, for example:

“The book was great; I learned so much about people as well as different cultures. What an amazing author and man.”

“I really love this book, and it’s quite a rare combination, an account of a daughter’s commitment to her dying father. The book was pleasurable to read, and Mike Smith writes gorgeously.”

“I liked the book but not very much; it’s just a book of a wonderful man, father, and grandfather. It’s also a book about diverse cultures. The author doesn’t have acute observations, and sympathy isn’t all that put together to bring the real picture of sad moments. It wasn’t achieved so well I’d say”

2)    Was it well written?

You can answer this question like this:

“The book is an account showing to what depths human beings can go to achieve something meaningful or worthy. The book is simply a well-written account depicting the struggle that human beings can reach. The book doesn’t, however, add anything significant to our knowledge-based regarding the first settlers of Poland.”

“It’s a well-written book, and it drew me from the very beginning. It made me feel like I was standing right there with them as they seek the treasures of the land. There are a lot of good books, and this is one of them actually. I truly enjoyed every part of it. Its rather crazy and fanciful story, though, but at its core, it unveils all aspects of today’s world and how human beings are, typically. It’s a powerful book.”

3)    What was the book’s genre?

Was the book a satire or an anthology which is among the most interesting genres, was it on this list? Philosophy, Biography, Business, Chick Lit, Children's, Christianity, Classics, Comics, Contemporary, Cookbooks, Crime, E-books, Fantasy, Fiction, Gay and Lesbian, Graphic Novels, Ancient Fiction, History, Horror, and finally thought the list could never be exhausted; Humor and Comedy.

4)   Who were the main characters?

 In fiction, which characters did play the most vital roles that intertwine well with the book's overall theme?

William Brown (The Travelling Horn Player)

William is a rebel child in Suburbia. His overall instincts are against what is termed as social-climbing and the humdrum. He has a way of befriending the outcasts.

Flashman (The Discworld Series)

Harry is funny, more honest, and ideally less harmful than the many brave fools whose paths he double-crosses. He is just an admirable rogue

5)    Did you notice ant reoccurring symbols?

In the book “The Old Man and The Sea,” lions are depicted to symbolize the youth, freedom, and immeasurable strength. 

The novella starts with the dream of Santiago, who dreamt about the lion on the beach. 

The lion does represent a hunter who is very wild, noble, and quite manly in nature and the lord and king of that specific area he is living in.

The lions also serve as a symbol of Santiago’s childhood as he reminisces seeing them on the beachside in Africa as he was sailing there as a youth man.

6)    Is the book part of a series?

Is the book part of a more significant collection of books? For example, Harry potter, hunger games, lord of the rings, a song of ice and fire, among other interesting book series ever produced.

7)    For non-fiction books, can you identify the writer’s thesis?

It’s essential to identify the thesis when it comes to non-fiction books. Typically you can simply identify this by being keen when a stance is developed that related to the topic of the book.

8)    What writing style is used in the book?

Does the author use expository writing, narrative writing, persuasive, or descriptive writing? Have you seen instances where the author has used more than one style of writing?

9)    Can a tone be noticeable in the book?

Has the author conveyed a tone in the book? For example, a tone can be introduced in a story using an adjective, which brings forth a feeling of fear, anxiety, excitement, worry. Foolish, smart or depressing moments

10)    Did you happen to come across intentional biases or slant?

You can easily detect bias and prejudice:

• Did the author use inflammatory text, for example, racial descriptions and slurs?

• Did the author make claims to demean?

• Did the author provide evidence which openly is meant to support one side while ignoring information that may demean what the author is trying to support?

11)    Conclusion of a 4th grade 4 paragraph book report.

There is not going to be a change in the conclusion that the few pages synopsis did not tell us. Read the book and then summarize it.

As you are concluding, consider to add the following impressions and opinions:

• Was the ending quite satisfactory for fiction stories?

• Did the evidence actively support the thesis? (Still in non-fiction)

• What facts can be noted as being interesting as far as the author is concerned?

• Finally, would you ever recommend this book to anyone?

Make sure that your conclusion covers an additional paragraph with these additional points. You can re-state the name of the author in this section as well (this entirely depends with your rubric)

Sample 4 paragraph book report 4 th grade

“This book I read was fascinating. Full of so many things. It had all of the makings of a great book. The story...really interesting. All of the characters had their own role to play. The conclusion was one of the best I've ever read." - DT 4 paragraph book report, c. 4th grade.

• Did you find the book to be enjoyable?

• Was it well written?

• Did you notice ant reoccurring symbols?

• Who were the main characters?

• Did you happen to come across intentional biases or slant?

• Is the book part of a series?

• For non-fiction books, can you identify the writer’s thesis?

• What writing style is used in the book?

• Can a tone be noticeable in the book?

• What was the book’s genre?

• Conclusion

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Sat / act prep online guides and tips, how to write an a+ argumentative essay.

Miscellaneous

You'll no doubt have to write a number of argumentative essays in both high school and college, but what, exactly, is an argumentative essay and how do you write the best one possible? Let's take a look.

A great argumentative essay always combines the same basic elements: approaching an argument from a rational perspective, researching sources, supporting your claims using facts rather than opinion, and articulating your reasoning into the most cogent and reasoned points. Argumentative essays are great building blocks for all sorts of research and rhetoric, so your teachers will expect you to master the technique before long.

But if this sounds daunting, never fear! We'll show how an argumentative essay differs from other kinds of papers, how to research and write them, how to pick an argumentative essay topic, and where to find example essays. So let's get started.

What Is an Argumentative Essay? How Is it Different from Other Kinds of Essays?

There are two basic requirements for any and all essays: to state a claim (a thesis statement) and to support that claim with evidence.

Though every essay is founded on these two ideas, there are several different types of essays, differentiated by the style of the writing, how the writer presents the thesis, and the types of evidence used to support the thesis statement.

Essays can be roughly divided into four different types:

#1: Argumentative #2: Persuasive #3: Expository #4: Analytical

So let's look at each type and what the differences are between them before we focus the rest of our time to argumentative essays.

Argumentative Essay

Argumentative essays are what this article is all about, so let's talk about them first.

An argumentative essay attempts to convince a reader to agree with a particular argument (the writer's thesis statement). The writer takes a firm stand one way or another on a topic and then uses hard evidence to support that stance.

An argumentative essay seeks to prove to the reader that one argument —the writer's argument— is the factually and logically correct one. This means that an argumentative essay must use only evidence-based support to back up a claim , rather than emotional or philosophical reasoning (which is often allowed in other types of essays). Thus, an argumentative essay has a burden of substantiated proof and sources , whereas some other types of essays (namely persuasive essays) do not.

You can write an argumentative essay on any topic, so long as there's room for argument. Generally, you can use the same topics for both a persuasive essay or an argumentative one, so long as you support the argumentative essay with hard evidence.

Example topics of an argumentative essay:

• "Should farmers be allowed to shoot wolves if those wolves injure or kill farm animals?"
• "Should the drinking age be lowered in the United States?"
• "Are alternatives to democracy effective and/or feasible to implement?"

The next three types of essays are not argumentative essays, but you may have written them in school. We're going to cover them so you know what not to do for your argumentative essay.

Persuasive Essay

Persuasive essays are similar to argumentative essays, so it can be easy to get them confused. But knowing what makes an argumentative essay different than a persuasive essay can often mean the difference between an excellent grade and an average one.

Persuasive essays seek to persuade a reader to agree with the point of view of the writer, whether that point of view is based on factual evidence or not. The writer has much more flexibility in the evidence they can use, with the ability to use moral, cultural, or opinion-based reasoning as well as factual reasoning to persuade the reader to agree the writer's side of a given issue.

Instead of being forced to use "pure" reason as one would in an argumentative essay, the writer of a persuasive essay can manipulate or appeal to the reader's emotions. So long as the writer attempts to steer the readers into agreeing with the thesis statement, the writer doesn't necessarily need hard evidence in favor of the argument.

Often, you can use the same topics for both a persuasive essay or an argumentative one—the difference is all in the approach and the evidence you present.

Example topics of a persuasive essay:

• "Should children be responsible for their parents' debts?"
• "Should cheating on a test be automatic grounds for expulsion?"
• "How much should sports leagues be held accountable for player injuries and the long-term consequences of those injuries?"

Expository Essay

An expository essay is typically a short essay in which the writer explains an idea, issue, or theme , or discusses the history of a person, place, or idea.

This is typically a fact-forward essay with little argument or opinion one way or the other.

Example topics of an expository essay:

• "The History of the Philadelphia Liberty Bell"
• "The Reasons I Always Wanted to be a Doctor"
• "The Meaning Behind the Colloquialism ‘People in Glass Houses Shouldn't Throw Stones'"

Analytical Essay

An analytical essay seeks to delve into the deeper meaning of a text or work of art, or unpack a complicated idea . These kinds of essays closely interpret a source and look into its meaning by analyzing it at both a macro and micro level.

This type of analysis can be augmented by historical context or other expert or widely-regarded opinions on the subject, but is mainly supported directly through the original source (the piece or art or text being analyzed) .

Example topics of an analytical essay:

• "Victory Gin in Place of Water: The Symbolism Behind Gin as the Only Potable Substance in George Orwell's 1984"
• "Amarna Period Art: The Meaning Behind the Shift from Rigid to Fluid Poses"
• "Adultery During WWII, as Told Through a Series of Letters to and from Soldiers"

There are many different types of essay and, over time, you'll be able to master them all.

A Typical Argumentative Essay Assignment

The average argumentative essay is between three to five pages, and will require at least three or four separate sources with which to back your claims . As for the essay topic , you'll most often be asked to write an argumentative essay in an English class on a "general" topic of your choice, ranging the gamut from science, to history, to literature.

But while the topics of an argumentative essay can span several different fields, the structure of an argumentative essay is always the same: you must support a claim—a claim that can reasonably have multiple sides—using multiple sources and using a standard essay format (which we'll talk about later on).

This is why many argumentative essay topics begin with the word "should," as in:

• "Should all students be required to learn chemistry in high school?"
• "Should children be required to learn a second language?"
• "Should schools or governments be allowed to ban books?"

These topics all have at least two sides of the argument: Yes or no. And you must support the side you choose with evidence as to why your side is the correct one.

But there are also plenty of other ways to frame an argumentative essay as well:

• "Does using social media do more to benefit or harm people?"
• "Does the legal status of artwork or its creators—graffiti and vandalism, pirated media, a creator who's in jail—have an impact on the art itself?"
• "Is or should anyone ever be ‘above the law?'"

Though these are worded differently than the first three, you're still essentially forced to pick between two sides of an issue: yes or no, for or against, benefit or detriment. Though your argument might not fall entirely into one side of the divide or another—for instance, you could claim that social media has positively impacted some aspects of modern life while being a detriment to others—your essay should still support one side of the argument above all. Your final stance would be that overall , social media is beneficial or overall , social media is harmful.

If your argument is one that is mostly text-based or backed by a single source (e.g., "How does Salinger show that Holden Caulfield is an unreliable narrator?" or "Does Gatsby personify the American Dream?"), then it's an analytical essay, rather than an argumentative essay. An argumentative essay will always be focused on more general topics so that you can use multiple sources to back up your claims.

Good Argumentative Essay Topics

So you know the basic idea behind an argumentative essay, but what topic should you write about?

Again, almost always, you'll be asked to write an argumentative essay on a free topic of your choice, or you'll be asked to select between a few given topics . If you're given complete free reign of topics, then it'll be up to you to find an essay topic that no only appeals to you, but that you can turn into an A+ argumentative essay.

What makes a "good" argumentative essay topic depends on both the subject matter and your personal interest —it can be hard to give your best effort on something that bores you to tears! But it can also be near impossible to write an argumentative essay on a topic that has no room for debate.

As we said earlier, a good argumentative essay topic will be one that has the potential to reasonably go in at least two directions—for or against, yes or no, and why . For example, it's pretty hard to write an argumentative essay on whether or not people should be allowed to murder one another—not a whole lot of debate there for most people!—but writing an essay for or against the death penalty has a lot more wiggle room for evidence and argument.

A good topic is also one that can be substantiated through hard evidence and relevant sources . So be sure to pick a topic that other people have studied (or at least studied elements of) so that you can use their data in your argument. For example, if you're arguing that it should be mandatory for all middle school children to play a sport, you might have to apply smaller scientific data points to the larger picture you're trying to justify. There are probably several studies you could cite on the benefits of physical activity and the positive effect structure and teamwork has on young minds, but there's probably no study you could use where a group of scientists put all middle-schoolers in one jurisdiction into a mandatory sports program (since that's probably never happened). So long as your evidence is relevant to your point and you can extrapolate from it to form a larger whole, you can use it as a part of your resource material.

And if you need ideas on where to get started, or just want to see sample argumentative essay topics, then check out these links for hundreds of potential argumentative essay topics.

101 Persuasive (or Argumentative) Essay and Speech Topics

301 Prompts for Argumentative Writing

Top 50 Ideas for Argumentative/Persuasive Essay Writing

[Note: some of these say "persuasive essay topics," but just remember that the same topic can often be used for both a persuasive essay and an argumentative essay; the difference is in your writing style and the evidence you use to support your claims.]

KO! Find that one argumentative essay topic you can absolutely conquer.

Argumentative Essay Format

Argumentative Essays are composed of four main elements:

• A position (your argument)
• Your reasons
• Supporting evidence for those reasons (from reliable sources)
• Counterargument(s) (possible opposing arguments and reasons why those arguments are incorrect)

If you're familiar with essay writing in general, then you're also probably familiar with the five paragraph essay structure . This structure is a simple tool to show how one outlines an essay and breaks it down into its component parts, although it can be expanded into as many paragraphs as you want beyond the core five.

The standard argumentative essay is often 3-5 pages, which will usually mean a lot more than five paragraphs, but your overall structure will look the same as a much shorter essay.

An argumentative essay at its simplest structure will look like:

Paragraph 1: Intro

• Set up the story/problem/issue
• Thesis/claim

Paragraph 2: Support

• Reason #1 claim is correct
• Supporting evidence with sources

Paragraph 3: Support

• Reason #2 claim is correct

Paragraph 4: Counterargument

• Explanation of argument for the other side
• Refutation of opposing argument with supporting evidence

Paragraph 5: Conclusion

• Re-state claim
• Sum up reasons and support of claim from the essay to prove claim is correct

Now let's unpack each of these paragraph types to see how they work (with examples!), what goes into them, and why.

Paragraph 1—Set Up and Claim

Your first task is to introduce the reader to the topic at hand so they'll be prepared for your claim. Give a little background information, set the scene, and give the reader some stakes so that they care about the issue you're going to discuss.

Next, you absolutely must have a position on an argument and make that position clear to the readers. It's not an argumentative essay unless you're arguing for a specific claim, and this claim will be your thesis statement.

Your thesis CANNOT be a mere statement of fact (e.g., "Washington DC is the capital of the United States"). Your thesis must instead be an opinion which can be backed up with evidence and has the potential to be argued against (e.g., "New York should be the capital of the United States").

Paragraphs 2 and 3—Your Evidence

These are your body paragraphs in which you give the reasons why your argument is the best one and back up this reasoning with concrete evidence .

The argument supporting the thesis of an argumentative essay should be one that can be supported by facts and evidence, rather than personal opinion or cultural or religious mores.

For example, if you're arguing that New York should be the new capital of the US, you would have to back up that fact by discussing the factual contrasts between New York and DC in terms of location, population, revenue, and laws. You would then have to talk about the precedents for what makes for a good capital city and why New York fits the bill more than DC does.

Your argument can't simply be that a lot of people think New York is the best city ever and that you agree.

In addition to using concrete evidence, you always want to keep the tone of your essay passionate, but impersonal . Even though you're writing your argument from a single opinion, don't use first person language—"I think," "I feel," "I believe,"—to present your claims. Doing so is repetitive, since by writing the essay you're already telling the audience what you feel, and using first person language weakens your writing voice.

For example,

"I think that Washington DC is no longer suited to be the capital city of the United States."

"Washington DC is no longer suited to be the capital city of the United States."

The second statement sounds far stronger and more analytical.

Paragraph 4—Argument for the Other Side and Refutation

Even without a counter argument, you can make a pretty persuasive claim, but a counterargument will round out your essay into one that is much more persuasive and substantial.

By anticipating an argument against your claim and taking the initiative to counter it, you're allowing yourself to get ahead of the game. This way, you show that you've given great thought to all sides of the issue before choosing your position, and you demonstrate in multiple ways how yours is the more reasoned and supported side.

Paragraph 5—Conclusion

This paragraph is where you re-state your argument and summarize why it's the best claim.

Briefly touch on your supporting evidence and voila! A finished argumentative essay.

Your essay should have just as awesome a skeleton as this plesiosaur does. (In other words: a ridiculously awesome skeleton)

Argumentative Essay Example: 5-Paragraph Style

It always helps to have an example to learn from. I've written a full 5-paragraph argumentative essay here. Look at how I state my thesis in paragraph 1, give supporting evidence in paragraphs 2 and 3, address a counterargument in paragraph 4, and conclude in paragraph 5.

Topic: Is it possible to maintain conflicting loyalties?

Paragraph 1

It is almost impossible to go through life without encountering a situation where your loyalties to different people or causes come into conflict with each other. Maybe you have a loving relationship with your sister, but she disagrees with your decision to join the army, or you find yourself torn between your cultural beliefs and your scientific ones. These conflicting loyalties can often be maintained for a time, but as examples from both history and psychological theory illustrate, sooner or later, people have to make a choice between competing loyalties, as no one can maintain a conflicting loyalty or belief system forever.

The first two sentences set the scene and give some hypothetical examples and stakes for the reader to care about.

The third sentence finishes off the intro with the thesis statement, making very clear how the author stands on the issue ("people have to make a choice between competing loyalties, as no one can maintain a conflicting loyalty or belief system forever." )

Paragraphs 2 and 3

Psychological theory states that human beings are not equipped to maintain conflicting loyalties indefinitely and that attempting to do so leads to a state called "cognitive dissonance." Cognitive dissonance theory is the psychological idea that people undergo tremendous mental stress or anxiety when holding contradictory beliefs, values, or loyalties (Festinger, 1957). Even if human beings initially hold a conflicting loyalty, they will do their best to find a mental equilibrium by making a choice between those loyalties—stay stalwart to a belief system or change their beliefs. One of the earliest formal examples of cognitive dissonance theory comes from Leon Festinger's When Prophesy Fails . Members of an apocalyptic cult are told that the end of the world will occur on a specific date and that they alone will be spared the Earth's destruction. When that day comes and goes with no apocalypse, the cult members face a cognitive dissonance between what they see and what they've been led to believe (Festinger, 1956). Some choose to believe that the cult's beliefs are still correct, but that the Earth was simply spared from destruction by mercy, while others choose to believe that they were lied to and that the cult was fraudulent all along. Both beliefs cannot be correct at the same time, and so the cult members are forced to make their choice.

But even when conflicting loyalties can lead to potentially physical, rather than just mental, consequences, people will always make a choice to fall on one side or other of a dividing line. Take, for instance, Nicolaus Copernicus, a man born and raised in Catholic Poland (and educated in Catholic Italy). Though the Catholic church dictated specific scientific teachings, Copernicus' loyalty to his own observations and scientific evidence won out over his loyalty to his country's government and belief system. When he published his heliocentric model of the solar system--in opposition to the geocentric model that had been widely accepted for hundreds of years (Hannam, 2011)-- Copernicus was making a choice between his loyalties. In an attempt t o maintain his fealty both to the established system and to what he believed, h e sat on his findings for a number of years (Fantoli, 1994). But, ultimately, Copernicus made the choice to side with his beliefs and observations above all and published his work for the world to see (even though, in doing so, he risked both his reputation and personal freedoms).

These two paragraphs provide the reasons why the author supports the main argument and uses substantiated sources to back those reasons.

The paragraph on cognitive dissonance theory gives both broad supporting evidence and more narrow, detailed supporting evidence to show why the thesis statement is correct not just anecdotally but also scientifically and psychologically. First, we see why people in general have a difficult time accepting conflicting loyalties and desires and then how this applies to individuals through the example of the cult members from the Dr. Festinger's research.

The next paragraph continues to use more detailed examples from history to provide further evidence of why the thesis that people cannot indefinitely maintain conflicting loyalties is true.

Paragraph 4

Some will claim that it is possible to maintain conflicting beliefs or loyalties permanently, but this is often more a matter of people deluding themselves and still making a choice for one side or the other, rather than truly maintaining loyalty to both sides equally. For example, Lancelot du Lac typifies a person who claims to maintain a balanced loyalty between to two parties, but his attempt to do so fails (as all attempts to permanently maintain conflicting loyalties must). Lancelot tells himself and others that he is equally devoted to both King Arthur and his court and to being Queen Guinevere's knight (Malory, 2008). But he can neither be in two places at once to protect both the king and queen, nor can he help but let his romantic feelings for the queen to interfere with his duties to the king and the kingdom. Ultimately, he and Queen Guinevere give into their feelings for one another and Lancelot—though he denies it—chooses his loyalty to her over his loyalty to Arthur. This decision plunges the kingdom into a civil war, ages Lancelot prematurely, and ultimately leads to Camelot's ruin (Raabe, 1987). Though Lancelot claimed to have been loyal to both the king and the queen, this loyalty was ultimately in conflict, and he could not maintain it.

Here we have the acknowledgement of a potential counter-argument and the evidence as to why it isn't true.

The argument is that some people (or literary characters) have asserted that they give equal weight to their conflicting loyalties. The refutation is that, though some may claim to be able to maintain conflicting loyalties, they're either lying to others or deceiving themselves. The paragraph shows why this is true by providing an example of this in action.

Paragraph 5

Whether it be through literature or history, time and time again, people demonstrate the challenges of trying to manage conflicting loyalties and the inevitable consequences of doing so. Though belief systems are malleable and will often change over time, it is not possible to maintain two mutually exclusive loyalties or beliefs at once. In the end, people always make a choice, and loyalty for one party or one side of an issue will always trump loyalty to the other.

The concluding paragraph summarizes the essay, touches on the evidence presented, and re-states the thesis statement.

How to Write an Argumentative Essay: 8 Steps

Writing the best argumentative essay is all about the preparation, so let's talk steps:

#1: Preliminary Research

If you have the option to pick your own argumentative essay topic (which you most likely will), then choose one or two topics you find the most intriguing or that you have a vested interest in and do some preliminary research on both sides of the debate.

Do an open internet search just to see what the general chatter is on the topic and what the research trends are.

Did your preliminary reading influence you to pick a side or change your side? Without diving into all the scholarly articles at length, do you believe there's enough evidence to support your claim? Have there been scientific studies? Experiments? Does a noted scholar in the field agree with you? If not, you may need to pick another topic or side of the argument to support.

#2: Pick Your Side and Form Your Thesis

Now's the time to pick the side of the argument you feel you can support the best and summarize your main point into your thesis statement.

Your thesis will be the basis of your entire essay, so make sure you know which side you're on, that you've stated it clearly, and that you stick by your argument throughout the entire essay .

#3: Heavy-Duty Research Time

You've taken a gander at what the internet at large has to say on your argument, but now's the time to actually read those sources and take notes.

Check scholarly journals online at Google Scholar , the Directory of Open Access Journals , or JStor . You can also search individual university or school libraries and websites to see what kinds of academic articles you can access for free. Keep track of your important quotes and page numbers and put them somewhere that's easy to find later.

And don't forget to check your school or local libraries as well!

#4: Outline

Follow the five-paragraph outline structure from the previous section.

Fill in your topic, your reasons, and your supporting evidence into each of the categories.

Before you begin to flesh out the essay, take a look at what you've got. Is your thesis statement in the first paragraph? Is it clear? Is your argument logical? Does your supporting evidence support your reasoning?

By outlining your essay, you streamline your process and take care of any logic gaps before you dive headfirst into the writing. This will save you a lot of grief later on if you need to change your sources or your structure, so don't get too trigger-happy and skip this step.

Now that you've laid out exactly what you'll need for your essay and where, it's time to fill in all the gaps by writing it out.

Take it one step at a time and expand your ideas into complete sentences and substantiated claims. It may feel daunting to turn an outline into a complete draft, but just remember that you've already laid out all the groundwork; now you're just filling in the gaps.

If you have the time before deadline, give yourself a day or two (or even just an hour!) away from your essay . Looking it over with fresh eyes will allow you to see errors, both minor and major, that you likely would have missed had you tried to edit when it was still raw.

Take a first pass over the entire essay and try your best to ignore any minor spelling or grammar mistakes—you're just looking at the big picture right now. Does it make sense as a whole? Did the essay succeed in making an argument and backing that argument up logically? (Do you feel persuaded?)

If not, go back and make notes so that you can fix it for your final draft.

Once you've made your revisions to the overall structure, mark all your small errors and grammar problems so you can fix them in the next draft.

#7: Final Draft

Use the notes you made on the rough draft and go in and hack and smooth away until you're satisfied with the final result.

A checklist for your final draft:

• Formatting is correct according to your teacher's standards
• No errors in spelling, grammar, and punctuation
• Essay is the right length and size for the assignment
• The argument is present, consistent, and concise
• Each reason is supported by relevant evidence
• The essay makes sense overall

#8: Celebrate!

Once you've brought that final draft to a perfect polish and turned in your assignment, you're done! Go you!

Be prepared and ♪ you'll never go hungry again ♪, *cough*, or struggle with your argumentative essay-writing again. (Walt Disney Studios)

Good Examples of Argumentative Essays Online

Theory is all well and good, but examples are key. Just to get you started on what a fully-fleshed out argumentative essay looks like, let's see some examples in action.

Check out these two argumentative essay examples on the use of landmines and freons (and note the excellent use of concrete sources to back up their arguments!).

The Use of Landmines

A Shattered Sky

The Take-Aways: Keys to Writing an Argumentative Essay

At first, writing an argumentative essay may seem like a monstrous hurdle to overcome, but with the proper preparation and understanding, you'll be able to knock yours out of the park.

Remember the differences between a persuasive essay and an argumentative one, make sure your thesis is clear, and double-check that your supporting evidence is both relevant to your point and well-sourced . Pick your topic, do your research, make your outline, and fill in the gaps. Before you know it, you'll have yourself an A+ argumentative essay there, my friend.

What's Next?

Now you know the ins and outs of an argumentative essay, but how comfortable are you writing in other styles? Learn more about the four writing styles and when it makes sense to use each .

Understand how to make an argument, but still having trouble organizing your thoughts? Check out our guide to three popular essay formats and choose which one is right for you.

Ready to make your case, but not sure what to write about? We've created a list of 50 potential argumentative essay topics to spark your imagination.

Courtney scored in the 99th percentile on the SAT in high school and went on to graduate from Stanford University with a degree in Cultural and Social Anthropology. She is passionate about bringing education and the tools to succeed to students from all backgrounds and walks of life, as she believes open education is one of the great societal equalizers. She has years of tutoring experience and writes creative works in her free time.

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How to Write a Great Essay Hook, With Examples

When you’re writing an essay , you naturally want people to read it. Just like the baited hook on a fishing line entices fish, your essay’s hook engages readers and makes them want to keep reading your essay.

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What is an essay hook?

An essay hook is a sentence or two that piques the reader’s interest, compelling them to continue reading. In most cases, the hook is the first sentence or two, but it may be the entire opening paragraph. Hooks for essays are always in the first section because this is where the essay needs to hook its reader. If the reader isn’t engaged within the first few lines, they’ll likely stop reading.

An essay hook also sets the tone for the rest of your essay. For example, an unexpected statistic in an essay’s first line can tell the reader that the rest of the essay will dispel myths and shed light on the essay’s topic .

6 types of essay hooks

1 rhetorical questions.

Rhetorical questions are popular essay hooks because they make readers think. For example, an essay might start with the question “Is it ethical to eat animals?” Before reading the rest of the essay, the reader answers the question in their mind. As they continue to read, the writer’s arguments challenge the reader’s answer and may change their mind.

2 Fact/statistic

When an essay discusses scientific subjects, social issues, current events, or controversial subjects, a fact or statistic related to the essay’s topic can be a compelling hook. For example, an essay about elementary student literacy might hook readers with a statistic about the percentage of fourth graders that are proficient readers.

The hook could be a fact or statistic that’s well-known and frames the topic in a relatable way, or it could be a completely unexpected or seemingly unintuitive one that surprises the reader. In any case, they set the tone for the rest of the essay by supporting the writer’s position from the outset.

Quotes are often used as essay hooks because they’re succinct, often recognizable, and when they’re from an expert source, they can support the writer’s position.

For example, an analytical essay comparing two books might hook readers with a quote from one of the books’ authors that sets the tone for the rest of the essay and gives a glimpse into that author’s work.

Anecdotes are often used as hooks in personal essays. A personal story makes the essay relatable, creating familiarity with the reader that makes them want to read more. An example of an anecdote hook is a persuasive essay about rerouting traffic on campus that starts with a personal story of a vehicular close call.

5 Description

A description focuses on specific imagery related to the essay’s subject. For example, an argumentative essay in support of new recycling policies might hook readers with a bleak description of what happens to batteries and other hazardous materials when they aren’t recycled.

6 Common misconception

Similar to an unexpected fact, a hook that dispels a common misconception surprises the reader and educates them about something they likely misunderstood. For example, a compare-and-contrast essay about different mindfulness strategies might start with a common misconception about how mindfulness works.

Creating a hook for different writing prompts

Strong hooks for essays align with the essays’ tones, types, and topics. As you start working on an essay, think about your topic and goals for the essay. Are you trying to persuade the reader? Dispelling a common misconception can be the hook you need. Are you telling an entertaining personal story with bigger themes about your life experience? Start it off with an engaging anecdote. Are you defending a position? Share an unexpected fact and let the truth speak for itself.

Sometimes, it’s not easy to tell which kind of hook your essay needs. When this is the case, it can be helpful to write the rest of your essay, then come back to your introduction and write the kind of hook that would make you want to read that whole essay. Refer to your essay outline to ensure that it fits your essay goals.

Essay hook examples

• Is it too late to save our planet from climate change?
• Before I could speak, I sang.
• “If we are truly a great nation, the truth cannot destroy us.” —Nikole Hannah-Jones
• Contrary to popular belief, rats are among the most fastidious animals.
• I can’t be late for class—this could be the most important day of my life!

Essay hook FAQs

An essay hook is a sentence or two that grabs the reader’s attention and piques their interest, enticing them to continue reading.

What are the different types of essay hooks?

• Rhetorical questions
• Description
• Fact/statistic
• Common misconception

Why is it important to have a good essay hook?

It’s important that hooks for essays be well crafted, because in many cases, the reader won’t continue reading an essay if it doesn’t hold their interest. The hook grabs their attention and makes them want to read on.

How to Write a Literary Analysis Essay in 8 Quick Steps

A good literary analysis involves more than just summarizing a story or poem. It's about digging deep into the text to understand its themes, characters, and writing techniques. In this article, we'll explore how to do just that. Whether you're a seasoned pro or new to the game, these tips will help you learn how to write a literary analysis essay that'll impress your readers. Let's dive in!

How to Write a Literary Analysis Essay?

Writing a good literary analysis is like taking a closer look at a painting to understand what makes it beautiful. In this section, we'll break down the steps to help you write a literary analysis essay on a book or poem. We'll explore things like characters, themes, and writing style so you can really understand what the author is trying to say. If you’re in a hurry, our experts can write paper for you overnight according to your particular instructions.

Choose Your Original

Select a source that intrigues you or one assigned by your instructor. Opt for a work that resonates with you emotionally or intellectually, as this connection will fuel your evaluation and keep you engaged throughout the process. Whether it's a classic novel, a contemporary poem, or a play, ensure that the content is rich in themes, characters, and stylistic devices to provide ample material for scrutinizing.

Read Carefully and Analyze

Once you've chosen your source, read it attentively, making notes on significant passages, character developments, and recurring themes. Pay close attention to the author's writing style, language choices, and penmanship devices such as imagery, symbolism, and foreshadowing. Analyze how these elements contribute to the overall meaning and impact of the original, and consider how they evoke emotions or convey the author's message to the reader. If you need critical analysis essay examples , here are some compelling samples for your inspiration and motivation.

Formulate a Thesis Statement

After thoroughly analyzing the text, formulate a clear and concise thesis statement that encapsulates your interpretation or claim about the work. Your thesis should assert a specific claim or perspective regarding the work's meaning, theme, or literature elements, providing a roadmap for your composition and guiding your reader's understanding of your assignment's purpose.

Develop Your Argument

With your thesis statement in mind, develop a coherent argument supporting your text interpretation. Draw on evidence from the original, including quotations, plot details, and character interactions, to substantiate your claims and illustrate your examination. Consider how each piece of evidence contributes to your overall argument and use it to build a persuasive case for your interpretation of the material. By the way, you can ask our experts, ‘ do my PowerPoint presentation ,’ and our specialists will address such an assignment, too.

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Outline Your Document

Create a detailed outline that organizes your ideas and evidence logically and sequentially. Divide your paper into an introduction, body paragraphs, and conclusion, each addressing a specific aspect of your exploration. Outline the main points you'll discuss in each paragraph and the evidence you'll use to support them, ensuring a clear and structured progression of ideas throughout your document.

Write Your Introduction

Begin with an engaging introduction that provides context for your brainstorming and introduces your thesis statement to the reader. Hook your audience with an intriguing opening line or a thought-provoking question, then provide background information about the document and its author to orient your reader. Finally, present your thesis, outlining the main points you'll address in your speculation and setting the stage for the rest of your work.

Craft Your Body Paragraphs

In the main body, develop each point of your argument in separate paragraphs, providing evidence from the work to support your claims. Start each paragraph with a topic sentence that introduces the main idea or statement of the paragraph, then follow it with evidence from the original, such as quotations or textual survey, to illustrate and substantiate your point. Analyze each piece of evidence in relation to your thesis, explaining how it supports your interpretation of the source and contributes to your overall argument.

Conclude Thoughtfully

Finally, conclude your assignment with a thoughtful conclusion summarizing your arguments and reinforcing your thesis. Review the main points you've discussed in your paper, highlighting your key insights or discoveries about the text. Avoid introducing new information or arguments in your conclusion; reiterate the significance of your research and its broader implications for understanding the manuscript. End your work with a compelling closing statement that leaves a lasting impression on your reader and encourages further reflection on the work's meaning and significance. Shop for an essay for sale if both your schedule and budget are tight.

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What Is a Literary Analysis Essay?

It is a type of academic writing that examines and interprets a work, such as a novel, poem, or play. It aims to delve into the deeper layers of the text to uncover its themes, characters, symbolism, and stylistic devices.

What Is the Purpose of a Literary Analysis Essay?

The purpose of this essay is to critically analyze a piece of literature, providing insights into its meaning, significance, and artistic techniques employed by the author. By dissecting the elements of the text, the paper seeks to understand how they contribute to the overall message or purpose of the work.

How to Start off a Literary Analysis Essay?

To start off such an essay, begin by introducing the work and its author, providing context for the research. Then, craft a thesis statement that presents your interpretation or claim about the source's meaning or significance. Finally, outline the main points you'll address in your document to guide the reader through your composition.

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(Slip Opinion) OCTOBER TERM, 2023 Syllabus NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337. 1 SUPREME COURT OF THE UNITED STATES Syllabus FISCHER v. UNITED STATES CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT No. 23-5572. Argued April 16, 2024-Decided June 28, 2024 The Sarbanes-Oxley Act of 2002 imposes criminal liability on anyone who corruptly "alters, destroys, mutilates, or conceals a record, docu- ment, or other object, or attempts to do so, with the intent to impair the object's integrity or availability for use in an official proceeding." 18 U. S. C. §1512(c)(1). The next subsection extends that prohibition to anyone who “otherwise obstructs, influences, or impedes any official proceeding, or attempts to do so." §1512(c)(2). Petitioner Joseph Fischer was charged with violating §1512(c)(2) for his conduct on Jan- uary 6, 2021. On that day, Congress convened in a joint session to certify the votes in the 2020 Presidential election. While they did so, a crowd of supporters of then-President Donald Trump gathered out- side the Capitol, and some eventually forced their way into the build- ing, breaking windows and assaulting police. App. 189. This breach of the Capitol delayed the certification of the vote. The criminal com- plaint alleges that Fischer was among those who invaded the building. Fischer was charged with various crimes for his actions on January 6, including obstructing an official proceeding in violation of §1512(c)(2). He moved to dismiss that charge, arguing that the provision criminal- izes only attempts to impair the availability or integrity of evidence. The District Court granted his motion in relevant part. A divided panel of the D. C. Circuit reversed and remanded for further proceed- ings. Held: To prove a violation of §1512(c)(2), the Government must establish that the defendant impaired the availability or integrity for use in an official proceeding of records, documents, objects, or other things used in an official proceeding, or attempted to do so. (a) To determine the scope of the residual “otherwise” clause in §1512(c)(2), the Court must decide how it is linked to its “surrounding

21 FISCHER v. UNITED STATES Syllabus words," Yates v. United States, 574 U. S. 528, 536 (plurality opinion), and "give effect, if possible, to every clause and word of [the] statute."" Williams v. Taylor, 529 U. S. 362, 404 (quoting United States v. Menasche, 348 U. S. 528, 538-539). The Court considers both "the spe- cific context" in which (c)(2) appears "and the broader context of the statute as a whole." Robinson v. Shell Oil Co., 519 U. S. 337, 341. (1) Section 1512(c)(1) describes particular types of criminal con- duct in specific terms. The purpose of (c)(2) is, as the parties agree, to cover some set of “matters not specifically contemplated" by (c)(1). Re- public of Iraq v. Beaty, 556 U. S. 848, 860. Perhaps Congress sought to criminalize all obstructive acts in §1512(c), and having named a few examples in (c)(1), devised (c)(2) to prohibit the rest. But (c)(2) could have a narrower scope if Congress designed it to fill inadvertent gaps in the focused language of (c)(1). One way to discern the reach of an “otherwise" clause is to look for guidance from whatever examples come before it. Two general princi- ples are relevant. First, the canon of noscitur a sociis teaches that a word is "given more precise content by the neighboring words with which it is associated." United States v. Williams, 553 U. S. 285, 294. And under the related canon of ejusdem generis, a general or collective term at the end of a list of specific items is typically controlled and defined by reference to those specific items that precede it. Southwest Airlines Co. v. Saxon, 596 U. S. 450, 458. These approaches to statu- tory interpretation track the common sense intuition that Congress would not ordinarily introduce a general term that renders meaning- less the specific text that accompanies it. Under these principles, the "otherwise" provision of §1512(c)(2) is limited by the list of specific criminal violations that precede it in (c)(1). If, as the Government asserts, (c)(2) covers all forms of obstructive con- duct beyond $1512(c)(1)'s focus on evidence impairment, Congress would have had little reason to provide any specific examples at all. And the sweep of subsection (c)(2) would swallow (c)(1), leaving that narrower provision with no work to do. Tethering subsection (c)(2) to the context of (c) (1) recognizes the dis- tinct purpose of each provision. Subsection (c)(1) refers to a defined set of offense conduct-four types of actions that, by their nature, im- pair the integrity or availability of records, documents, or objects for use in an official proceeding. Reading the "otherwise" clause as having been given more precise content by (c)(1), subsection (c)(2) makes it a crime to impair the availability or integrity of records, documents, or objects used in an official proceeding in ways other than those specified in (c)(1). For example, it is possible to violate (c)(2) by creating false evidence rather than altering incriminating evidence. Subsection

Cite as: 603 U. S. (2024) Syllabus 3 (c)(2) also ensures that liability is still imposed for impairing the avail- ability or integrity of other things used in an official proceeding beyond the "record[s], document[s], or other object[s]" enumerated in (c)(1), such as witness testimony or intangible information. (2) It makes sense to read (c)(2) as limited by (c)(1) in light of the history of the provision. The Enron accounting scandal exposed a loop- hole in §1512. At that time, the statute imposed liability on anyone who, among other things, corruptly persuaded another person to shred documents. But it curiously failed to impose liability on a person who destroyed records himself. The parties agree that Congress enacted §1512(c) as part of the broader Sarbanes-Oxley Act to plug this loop- hole. It would be peculiar to conclude that in closing the Enron gap, Congress created a catch-all provision that reaches beyond the scenar- ios that prompted the legislation. (b) The broader context of §1512 in the criminal code confirms that (c)(2) is limited by the scope of (c)(1). Federal obstruction law consists of numerous provisions that target specific criminal acts and settings, much of which would be unnecessary if (c)(2) criminalized essentially all obstructive conduct. Given the Court's obligation to give meaning where possible to each word and provision in the Code, Taylor, 529 U. S., at 404, the Court's narrower interpretation of subsection (c)(2) is the superior one. An unbounded interpretation of subsection (c)(2) would also render superfluous the careful delineation of different types of obstructive conduct in §1512 itself. That section provides a reticulated list of nearly two dozen means of committing obstruction with penalties ranging from three years to life in prison, or even death. The Govern- ment's reading would lump together under (c)(2) disparate types of conduct for which Congress had assigned proportionate sentences. (c) The Government's theory would also criminalize a broad swath of prosaic conduct, exposing activists and lobbyist to decades in prison. Our usual approach in obstruction cases has been to "resist reading" particular sub-provisions "to create a coverall statute." Yates, 574 U. S., at 549 (plurality opinion). Nothing in the text or statutory his- tory gives the Court a reason to depart from that practice today. And the Government's interpretation would give prosecutors broad discre- tion to seek a 20-year maximum sentence for acts Congress saw fit to punish with far shorter sentences. By reading (c)(2) in light of (c)(1), the Court affords proper respect to “the prerogatives of Congress” in carrying out the quintessentially legislative act of defining crimes and setting the penalties for them. United States v. Aguilar, 515 U. S. 593, 600. 64 F. 4th 329, vacated and remanded.

4 FISCHER v. UNITED STATES Syllabus ROBERTS, C. J., delivered the opinion of the Court, in which THOMAS, ALITO, GORSUCH, KAVANAUGH, and JACKSON, JJ., joined. JACKSON, J., filed a concurring opinion. BARRETT, J., filed a dissenting opinion, in which SOTOMAYOR and KAGAN, JJ., joined.

Cite as: 603 U. S. (2024) 1 Opinion of the Court NOTICE: This opinion is subject to formal revision before publication in the United States Reports. Readers are requested to notify the Reporter of Decisions, Supreme Court of the United States, Washington, D. Č. 20543, [email protected], of any typographical or other formal errors. SUPREME COURT OF THE UNITED STATES No. 23-5572 JOSEPH W. FISCHER, PETITIONER v. UNITED STATES ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT [June 28, 2024] CHIEF JUSTICE ROBERTS delivered the opinion of the Court. The Sarbanes-Oxley Act of 2002 imposes criminal liabil- ity on anyone who corruptly "alters, destroys, mutilates, or conceals a record, document, or other object, or attempts to do so, with the intent to impair the object's integrity or availability for use in an official proceeding.” 18 U. S. C. §1512(c)(1). The next subsection extends that prohibition to anyone who “otherwise obstructs, influences, or impedes any official proceeding, or attempts to do so." §1512(c)(2). We consider whether this “otherwise” clause should be read in light of the limited reach of the specific provision that precedes it. I This case concerns the prosecution of petitioner Joseph Fischer for his conduct on January 6, 2021. That day, both Houses of Congress convened in a joint session to certify the votes in the 2020 Presidential election. While they did so, a crowd of supporters of then-President Donald Trump gathered outside the Capitol. As set forth in the criminal complaint against Fischer, some of the crowd eventually

2 FISCHER v. UNITED STATES Opinion of the Court “forced entry” into the building, “breaking windows," and "assaulting members of the U. S. Capitol Police." App. 189. This breach of the Capitol caused Members of Congress to evacuate the Chambers and delayed the certification pro- cess. The complaint alleges that Fischer was one of those who invaded the building. According to the complaint, about an hour after the Houses recessed, Fischer trespassed into the Capitol and was involved in a physical confrontation with law enforce- ment. Fischer claimed in Facebook posts that he “pushed police back about 25 feet," and that he “was inside the [Cap- itol] talking to police." Id., at 193–194. Body camera foot- age shows Fischer near a scrum between the crowd and po- lice who were trying to eject trespassers from the building. Id., at 195-196. A grand jury returned a seven-count superseding indict- ment against Fischer. Six of those counts allege that Fischer forcibly assaulted a federal officer, entered and re- mained in a restricted building, and engaged in disorderly and disruptive conduct in the Capitol, among other crimes. See id., at 181-185; 18 U.S. C. §§111(a), 231(a)(3), 1752(a)(1), (a)(2); 40 U. S. C. §§5104(e)(2)(D), (G). Those six counts carry maximum penalties ranging from six months' to eight years' imprisonment. In Count Three, the only count now before us, the Gov- ernment charged Fischer with violating 18 U.S. C. §1512(c)(2). Fischer moved to dismiss that count, arguing that the provision criminalizes only attempts to impair the availability or integrity of evidence. The District Court granted his motion in relevant part. It concluded that the scope of Section 1512(c)(2) is limited by subsection (c)(1) and therefore requires the defendant to "have taken some action with respect to a document, record, or other object.' 2022 WL 782413, *4 (DC, Mar. 15, 2022) (quoting United States v. Miller, 589 F. Supp. 3d 60, 78 (DC 2022)). 999

Cite as: 603 U. S. (2024) 3 Opinion of the Court A divided panel of the D. C. Circuit reversed and re- manded for further proceedings. Judge Pan, writing for the court, held that the word “otherwise” in Section 1512(c)(2) means that the provision unambiguously covers "all forms of corrupt obstruction of an official proceeding, other than the conduct that is already covered by §1512(c)(1)." 64 F. 4th 329, 336 (2023). Judge Walker concurred in part and concurred in the judgment because he read the mens rea element of the statute—“corruptly”—as requiring a defend- ant to act with “an intent to procure an unlawful benefit." Id., at 361 (internal quotation marks omitted). Judge Katsas dissented. In his view, the language in sub- section (c)(1) narrows the language that comes after the word "otherwise" in subsection (c)(2). He therefore con- strued Section 1512(c)(2) as applying “only to acts that," like the ones specified in (c)(1), “affect the integrity or avail- ability of evidence” at an official proceeding. Id., at 363. We granted certiorari. 601 U. S. _ (2023). II The controversy before us is about the scope of the resid- ual "otherwise" clause in Section 1512(c)(2). On the one hand, Fischer contends that (c)(2) “applies only to acts that affect the integrity or availability of evidence." Brief for Pe- titioner 8. On the other, the Government argues that (c)(2) “capture[s] all forms of obstructive conduct beyond Section 1512(c)(1)'s focus on evidence impairment.” Brief for United States 13. Resolving such a dispute requires us to determine how the residual clause is linked to its “surrounding words." Yates v. United States, 574 U. S. 528, 536 (2015) (plurality opinion); see, e.g., United States v. Hansen, 599 U. S. 762, 774–775 (2023). In doing so, "we must ‘give effect, if possi- ble, to every clause and word of [the] statute.”” Williams v. Taylor, 529 U. S. 362, 404 (2000) (quoting United States v. Menasche, 348 U. S. 528, 538-539 (1955)). To that end, we

4 FISCHER v. UNITED STATES Opinion of the Court consider both "the specific context" in which (c)(2) appears "and the broader context of the statute as a whole." Robin- son v. Shell Oil Co., 519 U. S. 337, 341 (1997); see, e.g., Pul- sifer v. United States, 601 U. S. 124, 133 (2024) (choosing between “two grammatically permissible ways” to read a sentencing statute “by reviewing text in context"). A 1 Section 1512 provides: "(c) Whoever corruptly— "(1) alters, destroys, mutilates, or conceals a record, document, or other object, or attempts to do so, with the intent to impair the object's integrity or availability for use in an official proceeding; or "(2) otherwise obstructs, influences, or impedes any official proceeding, or attempts to do so, "shall be fined ... or imprisoned not more than 20 years, or both." Subsection (c)(1) describes particular types of criminal conduct in specific terms. To ensure the statute would not be read as excluding substantially similar activity not men- tioned, (c)(2) says it is also illegal to engage in some broader range of unenumerated conduct. The purpose of the "otherwise” clause is therefore, as the parties agree, to cover some set of "matters not specifically contemplated" by (c)(1). Republic of Iraq v. Beaty, 556 U. S. 848, 860 (2009); see Brief for Petitioner 12; Brief for United States 12-13. The problem is defining what exactly Con- gress left for (c)(2). Perhaps Congress sought to criminalize all obstructive acts in Section 1512(c), and having named a few examples in (c)(1), devised (c)(2) to prohibit the rest in one go. The point of (c)(1) would then be to illustrate just one type of conduct among many (c)(2) prohibits; it would be subsidiary to the overarching prohibition in (c)(2). But

Cite as: 603 U. S. (2024) 10 5 Opinion of the Court (c)(2) could well have a narrower scope if Congress designed it with the focused language of (c)(1) in mind. Subsection (c)(1) would then prohibit particular types of obstructive conduct and (c)(2) would fill any inadvertent gaps that might exist. One way to discern the reach of an "otherwise" clause is to look for guidance from whatever examples come before it. Two general principles are relevant. First, the canon of noscitur a sociis teaches that a word is "given more precise content by the neighboring words with which it is associ- ated." United States v. Williams, 553 U. S. 285, 294 (2008). That “avoid[s] ascribing to one word a meaning so broad that it is inconsistent with” “the company it keeps." Gus- tafson v. Alloyd Co., 513 U. S. 561, 575 (1995). And under the related canon of ejusdem generis, “a ‘general or collec- tive term' at the end of a list of specific items" is typically "controlled and defined by reference to the specific classes ... that precede it." Southwest Airlines Co. v. Saxon, 596 U. S. 450, 458 (2022) (quoting first Ali v. Federal Bureau of Prisons, 552 U. S. 214, 225 (2008); then Circuit City Stores, Inc. v. Adams, 532 U.S. 105, 115 (2001)); accord, Bis- sonnette v. LePage Bakeries Park St., LLC, 601 U. S. 246, 252 (2024). These approaches to statutory interpretation track the common sense intuition that Congress would not ordinarily introduce a general term that renders meaning- less the specific text that accompanies it. To see why, consider a straightforward example. A zoo might post a sign that reads, “do not pet, feed, yell or throw objects at the animals, or otherwise disturb them.” If a vis- itor eats lunch in front of a hungry gorilla, or talks to a friend near its enclosure, has he obeyed the regulation? Surely yes. Although the smell of human food or the sound of voices might well disturb gorillas, the specific examples of impermissible conduct all involve direct interaction with and harassment of the zoo animals. Merely eating or talk- ing is so unlike the examples that the zoo provided that it

6 FISCHER v. UNITED STATES Opinion of the Court would be implausible to assume those activities were pro- hibited, even if literally covered by the language. The idea is simply that a general phrase can be given a more focused meaning by the terms linked to it. That prin- ciple ensures- es-regardless of how complicated a sentence might appear—that none of its specific parts are made re- dundant by a clause literally broad enough to include them. See Yates, 574 U. S., at 545–546 (plurality opinion). For instance, a football league might adopt a rule that players must not "grab, twist, or pull a facemask, helmet, or other equipment with the intent to injure a player, or otherwise attack, assault, or harm any player.” If a linebacker shouts insults at the quarterback and hurts his feelings, has the linebacker nonetheless followed the rule? Of course he has. The examples of prohibited actions all concern dangerous physical conduct that might inflict bodily harm; trash talk is simply not of that kind. See 64 F. 4th, at 365-366 (Katsas, J., dissenting). Similarly improbable consequences can result from un- tethering an "otherwise” provision from the rest of a crimi- nal statute. Take Begay v. United States, 553 U. S. 137 (2008) (abrogated on other grounds by Johnson v. United States, 576 U.S. 591 (2015)). The question there was whether driving under the influence qualified as a "violent felony" under the Armed Career Criminal Act (ACCA). A “violent felony” was defined in relevant part by ACCA as a crime, punishable by more than a year's imprisonment, that "is burglary, arson, or extortion, involves use of explosives, or otherwise involves conduct that presents a serious poten- tial risk of physical injury to another."" 553 U. S., at 139– 140 (quoting 18 U. S. C. §924(e)(2)(B)(ii) (2000 ed.)). We recognized that, depending on the context, "the word 'oth- erwise' can"-though not “must”—“refer to a crime that is similar to the listed examples in some respects but different in others." 553 U. S., at 144 (emphasis deleted). And we held that while driving under the influence certainly may

Cite as: 603 U. S. (2024) 7 Opinion of the Court present a serious risk of physical injury, such an offense was so dissimilar from the previously enumerated exam- ples that it could not be classified as a “violent felony" under the statute. Id., at 142–146. The list of crimes that pre- ceded the residual clause-burglary, arson, extortion, and the use of explosives-focused on "purposeful, violent, and aggressive conduct." Id., at 144–145 (internal quotation marks omitted). And if that focus did not extend to the re- sidual clause, ACCA's 15-year mandatory minimum sen- tence would apply to a host of offenses “not typically com- mitted by those whom one normally labels ‘armed career criminals" and that were "far removed... from the delib- erate kind of behavior associated with violent criminal use of firearms.”¹ Id., at 146–147. The "otherwise" provision of Section 1512(c)(2) is simi- larly limited by the preceding list of criminal violations. The offenses enumerated in subsection (c)(1) cover someone who "alters, destroys, mutilates, or conceals a record, docu- ment, or other object . . . with the intent to impair the ob- ject's integrity or availability for use in an official proceed- ing." Complex as subsection (c)(1) may look, it simply consists of many specific examples of prohibited actions un- dertaken with the intent to impair an object's integrity or availability for use in an official proceeding: altering a rec- ord, altering a document, concealing a record, concealing a document, and so on. That list is followed immediately by a residual clause in (c)(2). Guided by the basic logic that Congress would not go to the trouble of spelling out the list in (c)(1) if a neighboring term swallowed it up, the most sen- 1 The dissent explains that we subsequently held the ACCA residual clause void for vagueness. See post, at 8 (opinion of BARRETT, J.) (citing Johnson v. United States, 576 U. S. 591, 597 (2015)). That our answer to the narrow question presented in Begay did not resolve a broader consti- tutional defect in the statute says little about whether the reasoning of Begay is relevant here.

00 8 FISCHER v. UNITED STATES Opinion of the Court sible inference is that the scope of (c)(2) is defined by refer- ence to (c)(1). If, as the Government asserts, (c)(2) covers "all forms of obstructive conduct beyond Section 1512(c)(1)'s focus on ev- idence impairment,” Brief for United States 13, there would have been scant reason for Congress to provide any specific examples at all. The sweep of subsection (c)(2) would con- sume (c)(1), leaving that narrower provision with no work to do. Indeed, subsection (c) (1) would be an elaborate pumpfake: a list of four types of highly particularized con- duct, performed with respect to a record, document, or ob- ject and “with the intent to impair the object's integrity or availability for use in an official proceeding,” followed in the very next subsection-in the same sentence, no less—by a superseding prohibition on all means of obstructing, influ- encing, or impeding any official proceeding. Construing Section 1512 in such a way gets the “familiar” analysis we apply to these types of statutes “exactly backwards,” elimi- nating specific terms because of broad language that follows them, rather than limiting the broad language in light of narrower terms that precede it. Bissonnette, 601 U. S., at 252, 255. Tethering subsection (c)(2) to the context of (c)(1) recog- nizes the distinct purpose of each provision. See A. Scalia & B. Garner, Reading Law 208 (2012) ("evident purpose" helps define scope of catchall provision). As we have ex- plained, subsection (c)(1) refers to a defined set of offense conduct—four types of actions that, by their nature, impair the integrity or availability of records, documents, or ob- jects for use in an official proceeding. When the phrase "otherwise obstructs, influences, or impedes any official proceeding" is read as having been given more precise con- tent by that narrower list of conduct, subsection (c)(2) makes it a crime to impair the availability or integrity of records, documents, or objects used in an official proceeding in ways other than those specified in (c)(1). For example, it

Cite as: 603 U. S. (2024) 9 Opinion of the Court is possible to violate (c)(2) by creating false evidence―ra- ther than altering incriminating evidence. See, e.g., United States v. Reich, 479 F. 3d 179, 185–187 (CA2 2007) (So- tomayor, J.) (prosecution under subsection (c)(2) for trans- mitting a forged court order). Subsection (c)(2) also ensures that liability is still imposed for impairing the availability or integrity of other things used in an official proceeding be- yond the "record[s], document[s], or other object[s]” enu- merated in (c)(1), such as witness testimony or intangible information. See, e.g., United States v. Mintmire, 507 F. 3d 1273, 1290 (CA11 2007) (prosecution under subsection (c)(2) based in part on the defendant's attempt to orches- trate a witness's grand jury testimony). The dissent supposes that because the word "otherwise" in (c)(2) can mean “in a different manner,” “by other means," or "in other respects," (c)(1) and (c) (2) are “distinct and independent prohibitions." Post, at 2, 5 (internal quo- tation marks omitted). But the word "otherwise" is not by itself "sufficient to demonstrate that the examples do not limit the scope of the clause." Begay, 553 U. S., at 144 (em- phasis deleted). “Otherwise” can link a set of examples to a general phrase and give it more definite meaning—even in statutory sentences that rival the complexity of Section 1512(c). See Finnegan v. Leu, 456 U. S. 431, 437–438 (1982); Breininger v. Sheet Metal Workers, 493 U. S. 67, 91– 92 (1989). 2 It makes sense to read subsection (c)(2) as limited by (c)(1) in light of the history of the provision. Prior to the Sarbanes-Oxley Act, Section 1512 imposed criminal liability on anyone who “knowingly uses intimida- tion or physical force, threatens, or corruptly persuades an- other person" to, among other things, shred documents. 18 U. S. C. §1512(b)(2)(B) (2000 ed.). But the Enron account- ing scandal revealed a loophole: Although Enron's "outside

10 10 FISCHER v. UNITED STATES Opinion of the Court auditor, Arthur Andersen LLP, had systematically de- stroyed potentially incriminating documents," the statute curiously failed to “impos[e] liability on a person who de- stroys records himself." Yates, 574 U. S., at 535-536 (plu- rality opinion). As a result, prosecutors had to prove that higher-ups at Enron and Arthur Andersen persuaded some- one else to shred documents rather than the more obvious theory that someone who shreds documents is liable for do- ing so. See S. Rep. No. 107–146, p. 7 (2002). The parties agree that to plug this loophole, Congress en- acted Section 1512(c)—the provision at issue here—as part of the broader Sarbanes-Oxley Act. It would be peculiar to conclude that in closing the Enron gap, Congress actually hid away in the second part of the third subsection of Sec- tion 1512 a catchall provision that reaches far beyond the document shredding and similar scenarios that prompted the legislation in the first place. The better conclusion is that subsection (c) (2) was designed by Congress to capture other forms of evidence and other means of impairing its integrity or availability beyond those Congress specified in (c)(1). B 1 The broader context of Section 1512 in the criminal code confirms that (c)(2) is limited by the scope of (c)(1). Federal obstruction law consists of numerous provisions that target specific criminal acts and settings. See 18 U. S. C. ch. 73. Much of that particularized legislation would be unneces- sary if (c)(2) criminalized essentially all obstructive con- duct, as the Government contends. Section 1503(a), for ex- ample, makes it a crime to "corruptly, or by threats or force, or by any threatening . . . communication, endeavor[] to in- fluence, intimidate, or impede” any juror or court officer. Section 1504 covers attempting to influence jurors through written communications. Section 1505 covers anyone who

Cite as: 603 U. S. (2024) 11 Opinion of the Court corruptly obstructs congressional inquiries or investiga- tions. Section 1507 covers picketing or parading in certain locations "with the intent of interfering with, obstructing, or impeding the administration of justice.” Section 1509 co- vers the obstruction of the exercise of rights or performance of duties under court orders. Section 1510(a) covers ob- struction of federal criminal investigations through bribery. Section 1511(a) covers certain obstruction of state or local law enforcement with the intent to facilitate illegal gam- bling. And Sections 1516, 1517, and 1518 address obstruc- tive acts in specific contexts, including federal audits, ex- aminations of financial institutions, and inquiries into healthcare-related offenses. If the Government were correct, then the "otherwise ob- structs, influences, or impedes any official proceeding" pro- vision—which is buried in subsection (c)(2) of Section 1512 would largely obviate the need for that broad array of other obstruction statutes. In light of our obligation to give meaning where possible to each word and provision in the Code, Taylor, 529 U. S., at 404, our narrower interpre- tation of subsection (c)(2) is the superior one. 2 An unbounded interpretation of subsection (c)(2) would also render superfluous the careful delineation of different types of obstructive conduct in Section 1512 itself. That section provides a reticulated list of nearly two dozen means of committing obstruction, with varying degrees of culpability and penalties ranging from three years to life in prison, or even death. Section 1512(a)(2)(B)(iv), for exam- ple, authorizes up to 30 years' imprisonment for someone who uses or attempts to use physical force against another person with the intent of causing him to be absent from an official proceeding. See §1512(a)(3)(B)(ii) (specifying pun- ishment). Section 1512(d)(1), by contrast, authorizes only

12 FISCHER v. UNITED STATES Opinion of the Court three years' imprisonment for someone who harasses an- other person and thereby dissuades him from attending an official proceeding. Reading (c)(2) to cover all forms of obstructive conduct would override Congress's careful delineation of which pen- alties were appropriate for which offenses. Most instances of those prohibited acts would instead fall under subsection (c)(2)'s sweeping reach, which provides a 20-year maximum term of imprisonment. Such a reading of subsection (c)(2) would lump together disparate types of conduct for which Congress had assigned proportionate penalties in (a)(2) and (d)(1).2 3 The Government's responses to this surplusage problem are not convincing. It first argues that because other provisions in Section 1512 would allow conviction in some circumstances on a "lesser mens rea than ‘corruptly,"" they have “a broader compass" than (c)(2). Brief for United States 34. For in- stance, the Government contends that subsection (b) can be violated by "knowing use of intimidation or threats, or mis- leading conduct." Id., at 35. But the Government concedes that "Congress did not define corruptly' for purposes of Sec- tion 1512." Id., at 44. And while the Government suggests that “corruptly” is “normally associated with wrongful, im- moral, depraved, or evil' conduct,” ibid. (quoting Arthur An- dersen LLP v. United States, 544 U. S. 696, 705 (2005)), it 292 2 The dissent maintains we have "glosse[d] over the absence of any prescribed minimum.' Post, at 14 (quoting Yates, 574 U. S., at 569 (KAGAN, J., dissenting)). Congress might have thought (c)(2) prohibited conduct of varying severity. But it does not follow that it designed (c)(2) to reach forms of conduct already covered in Chapter 73 with far lower maximum sentences. It would be improper to substitute for those fine- grained statutory distinctions the charging discretion of prosecutors and the sentencing discretion of district courts.

Cite as: 603 U. S. (2024) 13 Opinion of the Court never persuasively explains how “knowingly us[ing] intim- idation" or "threat[s]” against someone is not "wrongful." §1512(b). The same is true for most other subparts of Sec- tion 1512 that the Government identifies as having a lesser mens rea than (c)(2). Brief for United States 34; see, e.g., §1512(a)(1)(A) (criminalizing anyone who “kills or attempts to kill another person, with intent to" prevent attendance in an official proceeding); §1512(a)(2)(B)(iv) (criminalizing anyone who "uses physical force . . . against any person" in- tending to cause them to be absent from an official proceed- ing). None of those other provisions has a mens rea the Gov- ernment may more readily establish than the "corruptly" mens rea of subsection (c)(2). The Government also contends that its interpretation creates no surplusage because Section 1512's other “provi- sions sweep more broadly than an official proceeding.” Tr. of Oral Arg. 64; Brief for United States 34. To be sure, sub- sections (a)(2)(C), (b)(3), and (d)(2) criminalize various means of preventing someone from giving a judge or law enforcement officer information relating to the commission or possible commission of a federal offense or a violation of conditions of supervised release. And subsections (d)(3) and (4) make it a crime to harass someone and thereby dissuade them from arresting or prosecuting a person alleged to have committed a federal offense. None of these crimes requires an “official proceeding.” But not much if any conduct cov- ered by those provisions would escape the Government's ex- pansive interpretation of subsection (c)(2). For a person to have violated (c)(2), “an official proceeding need not be pending or about to be instituted.” §1512(f)(1). And be- cause interference with an arrest or with communications to authorities about federal offenses could very well ob- struct the initiation of future official proceedings, the Gov- ernment's reading of (c)(2) would still often consume viola- tions of (a)(2)(C), (b)(3), and (d)(2), (3), and (4).

14 FISCHER v. UNITED STATES Opinion of the Court The dissent tries to solve this surplusage problem by ar- guing that conduct only violates (c)(2) if it has a “relation- ship in time, causation, or logic”” with an official proceed- ing. Post, at 11 (quoting United States v. Aguilar, 515 U. S. 593, 599 (1995)). Assuming there is such a requirement, it would simply mean that the defendant's actions “must have the natural and probable effect” of interfering with the pro- ceeding. Id., at 599 (internal quotation marks omitted). Such a bar on prosecutions based on “speculative” theories of obstruction, id., at 601, would hardly cabin the reach of (c)(2). The dissent points out that our reading creates some sur- plusage, too. See post, at 12–13. In a wide-ranging scheme like Chapter 73, it is true that some provisions will inevita- bly cover some of the same conduct. But “surplusage is nonetheless disfavored,” and our “construction that creates substantially less of it is better than a construction that cre- ates substantially more.” 64 F. 4th, at 374 (Katsas, J., dis- senting). III On the Government's theory, Section 1512(c) consists of a granular subsection (c)(1) focused on obstructive acts that impair evidence and an overarching subsection (c)(2) that reaches all other obstruction. Even setting surplusage aside, that novel interpretation would criminalize a broad swath of prosaic conduct, exposing activists and lobbyists alike to decades in prison. As the Solicitor General acknowledged at oral argument, under the Government's interpretation, a peaceful protester could conceivably be charged under §1512(c)(2) and face a 20-year sentence. Tr. of Oral Arg. 51-52. And the Government would likewise have no apparent obstacle to prosecuting under (c)(2) any lobbying activity that “influences” an official proceeding and is undertaken “corruptly." Those peculiar results “un-

Cite as: 603 U. S. (2024) 15 Opinion of the Court derscore[] the implausibility of the Government's interpre- tation." Van Buren v. United States, 593 U. S. 374, 394 (2021). Our usual approach in obstruction cases has been to “re- sist reading” particular sub-provisions “to create a coverall" statute, as the Government would have us do here. Yates, 574 U. S., at 549 (plurality opinion); see also Marinello v. United States, 584 U. S. 1, 6-11 (2018); Arthur Andersen, 544 U. S., at 703-704. And there is no reason to depart from that practice today. Nothing in the text or statutory history suggests that subsection (c)(2) is designed to impose up to 20 years' imprisonment on essentially all defendants who commit obstruction of justice in any way and who might be subject to lesser penalties under more specific ob- struction statutes. See, e.g., §§1503(b)(3), 1505. If Con- gress had wanted to authorize such penalties for any con- duct that delays or influences a proceeding in any way, it would have said so. Instead, Section 1512 mentions "rec- ord," "document,” or other “object” 26 times. See 18 U. S. C. §§1512(a)(1)(B), (a)(2)(B)(i), (ii), (iii), 1512(b)(2)(A), (B), (C), 1512(c)(1), 1512(f). Rather than transforming this evidence-focused statute into a one-size-fits-all solution to obstruction of justice, we cabin our reading of subsection (c)(2) in light of the context of subsection (c)(1). Doing so affords proper respect to "the prerogatives of Congress" in carrying out the quintessen- tially legislative act of defining crimes and setting the pen- alties for them. Aguilar, 515 U. S., at 600. We have long recognized that “the power of punishment is vested in the legislative, not in the judicial department,” United States v. Wiltberger, 5 Wheat. 76, 95 (1820), and we have as a result “traditionally exercised restraint in assessing the reach of a federal criminal statute,”” Marinello, 584 U. S., at 11 (quoting Aguilar, 515 U. S., at 600). The Government's reading of Section 1512 would intrude on that deliberate arrangement of constitutional authority over federal

16 FISCHER v. UNITED STATES Opinion of the Court crimes, giving prosecutors broad discretion to seek a 20- year maximum sentence for acts Congress saw fit to punish only with far shorter terms of imprisonment—for example, three years for harassment under §1512(d)(1), or ten years for threatening a juror under §1503. For all these reasons, subsection (c)(2)'s “surrounding words" suggest that we should not give this “otherwise” pro- vision the broadest possible meaning. Yates, 574 U. S., at 536 (plurality opinion). Although the Government's all-en- compassing interpretation may be literally permissible, it defies the most plausible understanding of why (c)(1) and (c)(2) are conjoined, and it renders an unnerving amount of statutory text mere surplusage. Given that subsection (c)(2) was enacted to address the Enron disaster, not some further flung set of dangers, it is unlikely that Congress re- sponded with such an unfocused and “grossly incommensu- rate patch." 64 F. 4th, at 376 (Katsas, J., dissenting). We therefore decline to adopt the Government's interpretation, which is inconsistent with "the context from which the stat- ute arose." Bond v. United States, 572 U. S. 844, 860 (2014). * * * To prove a violation of Section 1512(c)(2), the Govern- ment must establish that the defendant impaired the avail- ability or integrity for use in an official proceeding of rec- ords, documents, objects, or as we earlier explained, other things used in the proceeding, or attempted to do so. See supra, at 9. The judgment of the D. C. Circuit is therefore vacated, and the case is remanded for further proceedings consistent with this opinion. On remand, the D. C. Circuit may assess the sufficiency of Count Three of Fischer's in- dictment in light of our interpretation of Section 1512(c)(2). It is so ordered.

Cite as: 603 U. S. (2024) 1 JACKSON, J., concurring SUPREME COURT OF THE UNITED STATES No. 23-5572 JOSEPH W. FISCHER, PETITIONER v. UNITED STATES ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT [June 28, 2024] JUSTICE JACKSON, concurring. On January 6, 2021, an angry mob stormed the United States Capitol seeking to prevent Congress from fulfilling its constitutional duty to certify the electoral votes in the 2020 Presidential election. See ante, at 1-2. The peaceful transfer of power is a fundamental democratic norm, and those who attempted to disrupt it in this way inflicted a deep wound on this Nation. But today's case is not about the immorality of those acts. Instead, the question before this Court is far narrower: What is the scope of the partic- ular crime Congress has outlined in 18 U. S. C. §1512(c)(2)? In the United States of America, “men are not subjected to criminal punishment because their conduct offends our patriotic emotions or thwarts a general purpose sought to be effected by specific commands which they have not diso- beyed. Nor are they to be held guilty of offenses which the statutes have omitted, though by inadvertence, to define and condemn." Viereck v. United States, 318 U. S. 236, 245 (1943). Our commitment to equal justice and the rule of law requires the courts to faithfully apply criminal laws as writ- ten, even in periods of national crisis, see, e.g., Cramer v. United States, 325 U. S. 1, 46-48 (1945), and even when the conduct alleged is indisputably abhorrent, cf. Michaels v. Davis, 601 U. S. (2024) (JACKSON, J., dissenting from denial of certiorari) (slip op., at 3).

2 FISCHER v. UNITED STATES JACKSON, J., concurring Notwithstanding the shocking circumstances involved in this case or the Government's determination that they war- rant prosecution, today, this Court's task is to determine what conduct is proscribed by the criminal statute that has been invoked as the basis for the obstruction charge at issue here. I join in the Court's opinion because I agree with the majority that §1512(c) (2) does not reach “all forms of ob- structive conduct”” and is, instead, “limited by the preced- ing list of criminal violations” in §1512(c)(1). Ante, at 7-8. I write separately to explain why and how that interpreta- tion of §1512(c) follows from the legislative purpose that this statute's text embodies. I Our goal in interpreting any statute should be "to give effect to the intent of Congress." United States v. American Trucking Assns., Inc., 310 U. S. 534, 542 (1940). There is no question that intent is generally expressed through the text of a statute. See American Tobacco Co. v. Patterson, 456 U. S. 63, 68 (1982). “[H]ewing closely to Congress's will" as embodied in the statute that it wrote "is especially important" when construing laws like this one, which im- plicate the possible imposition of punitive sanctions. Pugin v. Garland, 599 U. S. 600, 612 (2023) (JACKSON, J., concur- ring). Here, the majority rightly interprets the scope of §1512(c)(2) by “look[ing] for guidance from” the statutory "examples [that] come before" it those listed in §1512(c)(1). Ante, at 5. In my view, the examples that Con- gress opts to include in the text of a statute evince its inten- tions concerning what the rule covers and thereby help ex- press a particular legislative purpose. The majority's football-based example is illustrative. In a football league, says the majority, “a rule that players must not 'grab, twist, or pull a facemask, helmet, or other equipment with the intent to injure a player, or otherwise

Cite as: 603 U. S. (2024) 3 JACKSON, J., concurring attack, assault, or harm any player,”” should not be inter- preted as being directed at hurt feelings, because the listed "prohibited actions all concern dangerous physical conduct that might inflict bodily harm; trash talk is simply not of that kind." Ante, at 6. I agree. I would add that it is like- wise clear from the listed prohibited acts that such a rule is also not addressing far more serious and unexpected con- duct than the kinds of acts that the preceding examples de- scribe, which can result in serious and foreseeable physical injuries during a rough-and-tumble football game. By con- trast, if a player were to shoot or poison another player, the rule's drafters would expect the police to be called, not a referee. Thus, we conclude that the rule is best understood to be inapposite with respect to conduct at both extremes of the universe of harmful acts in which a player might con- ceivably engage. We recognize this intuitive fact that there is a certain category of conduct the rule is designed to prohibit-be- cause we recognize, albeit implicitly, that the drafters of this rule have included these particular examples for a rea- son. We understand that, given the preceding list of exam- ples, this rule was adopted with a clear intent concerning its scope. So, though a broad conception of "harm” is “liter- ally covered by the language” of the rule, ibid., we appreci- ate that the rule's drafters did not intend for that term to take on its most expansive meaning. Instead, the examples help illuminate what the drafters actually intended the rule to cover. From the preceding list, we can confidently dis- cern that the drafters meant to proscribe only conduct that risks injuries with severity akin to facemask pulling, not trash talk or murder.1 1 The majority invokes the canons of noscitur a sociis and ejusdem gen- eris to support this inference. See ante, at 5. Those canons are useful interpretive tools, but in my view, they are ultimately only devices used in furtherance of achieving our goal of determining “the intent of Con- gress." United States v. American Trucking Assns., Inc., 310 U. S. 534,

4 FISCHER v. UNITED STATES JACKSON, J., concurring The upshot is that, when interpreting the scope of a par- ticular statute or rule, our assessment of the words that the drafters used informs our understanding of what the rule was designed to do.² Discerning the rule's purpose is criti- cal when a court is called upon to interpret the provision. II Turning to the statutory provision at issue here, the pur- pose of $1512(c), reflected in its text, is clear. Subsection (c)(1) is indisputably focused on persons who engage in a particular kind of obstructive conduct: Anyone who "cor- ruptly alters, destroys, mutilates, or conceals a record, document, or other object, . . . with the intent to impair the object's integrity or availability for use in an official pro- ceeding." Subsection (c)(2), in turn, is directed at criminal conduct that “otherwise” achieves a similar result. I there- fore agree with the majority that §1512(c)(2)'s reach is nar- rower than the Government contends. As the majority holds, §1512(c)(2) “makes it a crime to impair the availabil- ity or integrity of records, documents, or objects used in an official proceeding in ways other than those specified in (c)(1)" and to “impai[r] the availability or integrity of other things used in an official proceeding beyond the 'record[s], document[s], or other object[s]' enumerated in (c)(1)." ... 542 (1940). "There is no invariable rule for the discovery of that inten- tion." Ibid. As one treatise explains, such canons are “not. rule[s] of law" but rather "one of various factors to be considered." A. Scalia & B. Garner, Reading Law: The Interpretation of Legal Texts 212 (2012); see also id., at 196–198. We apply these canons because we understand that their principles are consistent with how users of language—including legislators convey meaning. See id., at 212 ("Any lawyer or legislative drafter who writes two or more specifics followed by a general residual term without the intention that the residual term be limited may be guilty of malpractice"). As such, they are valid indicia of Congress's pur- pose. 2 Other indicia of the drafters' intent, such as the rule's context or en- actment history, can further inform our understanding of the rule. See infra, at 5-8.

Cite as: 603 U. S. (2024) JACKSON, J., concurring 10 5 Ante, at 8-9. This understanding of §1512(c)'s text and purpose is en- tirely consistent with the statute's enactment history. Con- gress enacted §1512(c) as part of the Sarbanes-Oxley Act, which "was prompted by the exposure of Enron's massive accounting fraud and revelations that the company's out- side auditor, Arthur Andersen LLP, had systematically de- stroyed potentially incriminating documents." Yates v. United States, 574 U. S. 528, 535–536 (2015) (plurality opinion). When introducing what later became §1512(c) on the Senate floor, Senator Lott emphasized that its principal purpose was to target document destruction, which was, at the time, prohibited “only if ... a subpoena ha[d] been is- sued for the evidence that ha[d] been destroyed or altered." 148 Cong. Rec. S6545 (July 10, 2002). “[T]his section,” he explained, "would allow the Government to charge obstruc- tion against individuals who acted alone, even if the tam- pering took place prior to the issuance of a grand jury sub- poena." Ibid. Similarly, the Senate Report accompanying the proposed statute noted that “current federal obstruction of justice statutes relating to document destruction [were] riddled with loopholes and burdensome proof require- ments." S. Rep. No. 107–146, p. 6 (2002). According to the Senate Report, §1512(c) was drafted to fill these gaps: "When a person destroys evidence with the intent of ob- structing any type of investigation and the matter is within the jurisdiction of a federal agency, overly technical legal distinctions should neither hinder nor prevent prosecution and punishment.” Id., at 7. Conversely, there is no indication whatsoever that Con- gress intended to create a sweeping, all-purpose obstruction statute. As the majority notes, "[f]ederal obstruction law consists of numerous provisions that target specific crimi- nal acts and settings." Ante, at 10. Outside of the Govern- ment's proposed interpretation of §1512(c), Congress has never enacted “a one-size-fits-all solution to obstruction of

6 FISCHER v. UNITED STATES JACKSON, J., concurring justice.” Ante, at 15.³ Meanwhile, many States have done just that. See J. Decker, The Varying Parameters of Ob- struction of Justice in American Criminal Law, 65 La. L. Rev. 49, 77, and n. 236 (2004) (collecting statutes). 4 The drafters of the Model Penal Code, too, proposed such a gen- eral obstruction crime. See ALI, Model Penal Code §242.1, p. 201 (1980) ("A person commits a misdemeanor if he pur- posely obstructs, impairs or perverts the administration of law or other governmental function by force, violence, phys- ical interference or obstacle, breach of official duty, or any other unlawful act"). Given that Congress has never before passed a similarly broad obstruction law when others have long existed, it is highly unlikely that Congress intended for subsection (c)(2) to establish a first-of-its-kind general federal obstruction crime. Nothing in the enactment history of §1512(c) sug- gests that Congress believed that it was creating an all-en- compassing statute that would obviate the need for any other obstruction prohibitions. This conclusion is further reinforced by the fact that, un- like §1512(c)(2), nearly all of the broad, all-purpose obstruc- tion statutes that various States have enacted are classified as misdemeanors. See, e.g., Colo. Rev. Stat. §18–8–102(3) (2023); Ohio Rev. Code Ann. 2921.31(B) (Lexis 2024). As a 3 That is not to say, of course, that Congress could not enact such a statute if it so chose. "We have traditionally exercised restraint in as- sessing the reach of a federal criminal statute. . . out of deference to the prerogatives of Congress,” United States v. Aguilar, 515 U. S. 593, 600 (1995), not because broad criminal proscriptions are beyond the scope of Congress's power. 4 See also, e.g., Colo. Rev. Stat. §18–8–102(1) (2023) ("A person commits obstructing government operations if he intentionally obstructs, impairs, or hinders the performance of a governmental function by a public serv- ant, by using or threatening to use violence, force, or physical interfer- ence or obstacle"); Ohio Rev. Code Ann. §2921.31(A) (Lexis 2024) ("No person... shall do any act that hampers or impedes a public official in the performance of the public official's lawful duties").

Cite as: 603 U. S. (2024) 7 JACKSON, J., concurring result, these types of obstruction crimes are generally pun- ishable by up to a year of incarceration. See 1 W. LaFave, J. Israel, N. King, & O. Kerr, Criminal Procedure §1.8(c), pp. 557-558 (4th ed. 2015). That is so for a reason: As the Model Penal Code's drafters explained, “the existence of a residual misdemeanor offense" allows for the “appropri- ately narrow definition of the serious forms of obstruction carrying felony penalties." §242.1, Comment 2, at 203. "A broad residual offense. . . provides a hedge against the in- genuity of offenders," since "[n]ot all forms of obstruction can be anticipated and precisely proscribed in specific of- fenses." Ibid. But, at the same time, that kind of broad criminal statute “must incorporate certain limitations lest it nullify policy decisions expressed elsewhere." Ibid. In other words, these broad misdemeanor obstruction statutes are “amalgam[s] of generality and constraint.” Ibid. The Government's interpretation of §1512(c)(2), by con- trast, exhibits all the generality of these catchall misde- meanor obstruction provisions while displaying none of their restraint. Section 1512(c)(2) is a felony, and it im- poses a 20-year maximum sentence-one of the more severe potential punishments in Chapter 73 of the U. S. Code. That stands in contrast with Congress's specification that other serious obstructive acts warrant “far shorter terms of imprisonment—for example, three years for harassment under §1512(d)(1), or ten years for threatening a juror un- der $1503." Ante, at 16. Finally, it is worth remembering the statutory context in which Congress chose to prohibit the obstruction-related conduct we are considering today. The statute Congress wrote addresses this matter in a 13-word phrase, enumer- ated "2," that is located within subsection (c) of a much broader §1512, which itself consists of “a reticulated list of nearly two dozen means of committing obstruction." Ante, at 11. However we might interpret Congress's drafting choices in other contexts, we should be wary of finding that

8 FISCHER v. UNITED STATES JACKSON, J., concurring a statute addresses significant criminal conduct when none of the available indicia of congressional intent, including the prohibition's placement, suggest that Congress in- tended that result. Here, it beggars belief that Congress would have inserted a breathtakingly broad, first-of-its- kind criminal obstruction statute (accompanied by a sub- stantial 20-year maximum penalty) in the midst of a signif- icantly more granular series of obstruction prohibitions without clarifying its intent to do so―not in the text of the provision itself, nor in the surrounding statutory context, nor in any statement issued during the enactment process. * * * In my view, the Court properly interprets §1512(c)(2) in the opinion it issues today. It also rightly vacates the judg- ment below and remands this case for further proceedings. Joseph Fischer was charged with violating §1512(c)(2) by corruptly obstructing “a proceeding before Congress, specif- ically, Congress's certification of the Electoral College vote." App. 183. That official proceeding plainly used certain rec- ords, documents, or objects—including, among others, those relating to the electoral votes themselves. See Tr. of Oral Arg. 65-67. And it might well be that Fischer's conduct, as alleged here, involved the impairment (or the attempted impairment) of the availability or integrity of things used during the January 6 proceeding “in ways other than those specified in (c)(1)." Ante, at 8. If so, then Fischer's prosecu- tion under $1512(c)(2) can, and should, proceed. That issue remains available for the lower courts to determine on re- mand.

Cite as: 603 U. S. (2024) 1 BARRETT, J., dissenting SUPREME COURT OF THE UNITED STATES No. 23-5572 JOSEPH W. FISCHER, PETITIONER v. UNITED STATES ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT [June 28, 2024] JUSTICE BARRETT, with whom JUSTICE SOTOMAYOR and JUSTICE KAGAN join, dissenting. Joseph Fischer allegedly joined a mob of rioters that breached the Capitol on January 6, 2021. At the time, Con- gress was meeting in a joint session to certify the Electoral College results. The riot forced Congress to suspend the proceeding, delaying it for several hours. The Court does not dispute that Congress's joint session qualifies as an “official proceeding”; that rioters delayed the proceeding; or even that Fischer's alleged conduct (which includes trespassing and a physical confrontation with law enforcement) was part of a successful effort to forcibly halt the certification of the election results. Given these prem- ises, the case that Fischer can be tried for “obstructing, in- fluencing, or impeding an official proceeding” seems open and shut. So why does the Court hold otherwise? Because it simply cannot believe that Congress meant what it said. Section 1512(c)(2) is a very broad provision, and admittedly, events like January 6th were not its target. (Who could blame Congress for that failure of imagination?) But statutes often go further than the problem that in- spired them, and under the rules of statutory interpreta- tion, we stick to the text anyway. The Court, abandoning that approach, does textual backflips to find some way—

2 FISCHER v. UNITED STATES BARRETT, J., dissenting any way to narrow the reach of subsection (c)(2). I re- spectfully dissent. I The case for the Government's interpretation is straight- forward. It can be accomplished in three paragraphs, as compared to the Court's many, many more. Ante, at 4-12. Start with the verbs: To "obstruct" and to “impede” mean to "hinder" or "retard" something's "passage" or "progress." 10 Oxford English Dictionary 668 (2d ed. 1989); 7 id., at 705. We have previously explained that these words are "broad." Marinello v. United States, 584 U. S. 1, 7 (2018). To “influence” is similarly expansive, meaning “[t]o affect the condition of” or “to have an effect on” something. 7 Ox- ford English Dictionary, at 940. The object of these verbs is an "official proceeding," defined to include “a proceeding be- fore the Congress." 18 U.S. C. §1515(a)(1)(B).¹ So (c)(2) covers all sorts of actions that affect or interfere with official proceedings. "[O]therwise," which introduces 18 U. S. C. §1512(c)(2), does not narrow its scope. “Otherwise” means “in a differ- ent manner,” “by other means,” or “in other respects." 10 Oxford English Dictionary, at 984; Webster's Third New In- ternational Dictionary 1598 (2002). It is often used to in- troduce a "catchall phras[e].” Texas Dept. of Housing and Community Affairs v. Inclusive Communities Project, 576 U. S. 519, 535 (2015). Here, “otherwise” tells the reader how (c)(1) and (c) (2) fit together. Subsection (c)(1) prohibits "alter[ing], destroy[ing], mutilat[ing], or conceal[ing] a rec- ord, document, or other object” with “intent to impair [its] integrity or availability for use in an official proceeding.” In other words, (c)(1) targets document and object spoliation— 1 The D. C. Circuit held, and this Court does not dispute, that Con- gress's joint session on January 6, 2021, qualifies as an "official proceed- ing."" 64 F. 4th 329, 342 (2023).

Cite as: 603 U. S. (2024) 3 BARRETT, J., dissenting classic means of obstruction. Subsection (c)(2) then prohib- its obstructing, influencing, or impeding an official proceed- ing by means different from those specified in (c)(1), thereby serving as a catchall. The “enumerated" crimes in (c)(1) and the "unenumerated crimes" in (c) (2) are similar “on one spe- cific dimension": "the particular similarity specified after the 'otherwise." Begay v. United States, 553 U. S. 137, 150–151 (2008) (Scalia, J., concurring in judgment). Here, that means that each crime represents one means through which to obstruct, influence, or impede an official proceed- ing. Joseph Fischer allegedly participated in a riot at the Cap- itol that forced the delay of Congress's joint session on Jan- uary 6th. Blocking an official proceeding from moving for- ward surely qualifies as obstructing or impeding the proceeding by means other than document destruction. Fischer's alleged conduct thus falls within (c)(2)'s scope. II A Opting for a narrower approach, the Court declines to take (c)(2) on its own terms. Instead, it borrows the eviden- tiary focus of (c)(1) to hold that a defendant violates (c)(2) only by "impair[ing] the availability or integrity for use in an official proceeding of records, documents, objects, or . . . other things used in the proceeding." Ante, at 16. Other means of obstructing a proceeding—say, by shutting it down are out. This interpretation might sound faithful to the statute, because the limit comes from a related provision rather than thin air. But snipping words from one subsection and grafting them onto another violates our normal interpretive principles. “[W]e ordinarily resist reading words or ele- ments into a statute that do not appear on its face."" Dean v. United States, 556 U. S. 568, 572 (2009) (quoting Bates v.

4 FISCHER v. UNITED STATES BARRETT, J., dissenting United States, 522 U. S. 23, 29 (1997)). And “[w]here Con- gress includes particular language in one section of a stat- ute but omits it in another section of the same Act,"" we generally presume that Congress did so intentionally. Rus- sello v. United States, 464 U. S. 16, 23 (1983) (quoting United States v. Wong Kim Bo, 472 F. 2d 720, 722 (CA5 1972) (per curiam)). The Court's reasons for departing from these rules are thin. 1 The Court begins with the noscitur a sociis and ejusdem generis canons. Ante, at 5. The noscitur canon counsels that "words grouped in a list should be given related mean- ings." A. Scalia & B. Garner, Reading Law §31, p. 195 (2012) (internal quotation marks omitted). It is particu- larly useful when interpreting “a word [that] is capable of many meanings."" McDonnell v. United States, 579 U. S. 550, 569 (2016) (quoting Jarecki v. G. D. Searle & Co., 367 U. S. 303, 307 (1961)). See, e.g., Gustafson v. Alloyd Co., 513 U. S. 561, 573–575 (1995) (employing the canon to in- terpret “communication” in the statutory list “prospectus, notice, circular, advertisement, letter, or communication""). The ejusdem canon applies when “a catchall phrase" follows “an enumeration of specifics, as in dogs, cats, horses, cattle, and other animals." Scalia & Garner §32, at 199. We often interpret the catchall phrase to “embrace only objects simi- lar in nature to those objects enumerated by the preceding specific words." Circuit City Stores, Inc. v. Adams, 532 U. S. 105, 115 (2001). See, e.g., Washington State Dept. of Social and Health Servs. v. Guardianship Estate of Keffeler, 537 U. S. 371, 375, 385 (2003) (employing the canon to construe the general term in the statutory list "execution, levy, at- tachment, garnishment, or other legal process""). These canons are valuable tools. But applying either to (c)(2) is like using a hammer to pound in a screw-it looks like it might work, but using it botches the job. Unlike the

Cite as: 603 U. S. (2024) 10 5 BARRETT, J., dissenting pattern to which the noscitur canon applies, §1512(c) is not a list of terms that includes an ambiguous word. So the Court does not do what it does when applying noscitur: se- lect between multiple accepted meanings of the words "ob- structs,” “influences,” and “impedes." Instead, it modifies those words by adding an adverbial phrase: obstructs, in- fluences or impedes by “impair[ing] the availability or in- tegrity for use in an official proceeding of records, docu- ments, or objects." Ante, at 16 (emphasis added). The ejusdem canon is an equally poor fit. Unlike the pattern to which ejusdem applies, (c)(2) is “not a general or collective term following a list of specific items to which a particular statutory command is applicable.” United States v. Aguilar, 515 U. S. 593, 615 (1995) (Scalia, J., concurring in part and dissenting in part). Instead, (c)(1) and (c)(2) are "distinct and independent prohibitions." Ibid. Though they share a subject and an adverb—“[w]hoever corruptly"-the two clauses contain different verbs that take different objects. §1512(c). Moreover, (c)(1) has a separate mens rea provi- sion that further disrupts the connection between the clauses. To my knowledge, we have never applied either of these canons to a statute resembling §1512(c). Rather than iden- tify such a case, the Court invents examples of a sign at the zoo and a football league rule. Ante, at 5-6. The zoo exam- ple ("do not pet, feed, yell or throw objects at the animals, or otherwise disturb them”) does not help, because it mim- ics the typical ejusdem format of specific words followed by a catchall. The list of specific verbs makes clear that the cleanup phrase (“otherwise disturb") is limited to conduct that involves direct interaction with the animals. But in the absence of a laundry list followed by a catchall, it is hard to see why the ejusdem canon fits. Ali v. Federal Bureau of Prisons, 552 U. S. 214, 225 (2008) ("The absence of a list of specific items undercuts the inference embodied in ejusdem

6 FISCHER v. UNITED STATES BARRETT, J., dissenting generis that Congress remained focused on the common at- tribute when it used the catchall phrase"). And §1512(c) does not follow the laundry-list-plus-catchall pattern. The Court's football example is only slightly better. As a refresher: "[A] football league might adopt a rule that players must not 'grab, twist, or pull a facemask, helmet, or other equipment with the intent to injure a player, or otherwise attack, assault, or harm any player.' If a linebacker shouts insults at the quarterback and hurts his feelings, has the linebacker nonetheless followed the rule? Of course he has. The examples of prohibited actions all concern dangerous physical conduct that might inflict bodily harm; trash talk is simply not of that kind." Ante, at 6. Put aside that it is hard to imagine anyone describing “trash talk” as inflicting an “injury” or “harming" a player in a football game. The league rule plainly forecloses the possibility. Consistent with the noscitur canon, “harm” takes its meaning from its companions “attack” and “as- sault." And while the Court tries to track §1512(c)'s struc- ture by adding an extra intent clause, the two clauses in its example are still tightly focused on actions directed at the player. (After all, who is wearing the facemask, helmet, or other equipment?) Given that shared theme, it is easy to understand that the first clause's focus on physical conduct limits the (only slightly) more general clause. But §1512(c)'s subsections are not so closely related―(c)(1) fo- cuses specifically on objects in a proceeding, and (c)(2) broadens the lens to the proceeding itself. Consider a rule that actually mirrors §1512(c): "Any player who: "(1) punches, chokes, or kicks an opposing player with the intent to remove him from the game; or "(2) otherwise interrupts, hinders, or interferes with

Cite as: 603 U. S. (2024) 7 the game, BARRETT, J., dissenting "shall be suspended." While the specific verbs in the first clause involve actions directed at an opposing player, the second clause is a sepa- rate prohibition with an entirely different object. Imagine that, just before the opposing team's kicker attempts a field goal, players leave the sidelines and storm the field, some tackling referees in the process. Those players have surely “interrupt[ed], hinder[ed], or interfer[ed] with the game,” even though they have not physically injured any opponent. This hypothetical, not the Court's, is analogous to §1512(c) and it supports the Government's interpretation. 2 The Court next recruits help from Begay, which inter- prets an "otherwise" clause in the Armed Career Criminal Act. Ante, at 6; 553 U. S., at 140. The ACCA defines a "vi- olent felony" as a felony that “is burglary, arson, or extor- tion, involves use of explosives, or otherwise involves con- duct that presents a serious potential risk of physical injury.” 18 U. S. C. §924(e)(2)(B)(ii). Begay holds that the example crimes limit the catchall clause to "crimes that are roughly similar . . . to the examples themselves." 553 U. S., at 143. So too here, the Court reasons, the list of crimes in (c)(1) limits the “otherwise” clause in (c)(2). But §1512(c) is structured differently than the statute in Begay. While §1512(c) contains two distinct criminal pro- hibitions (c)(1) and (c)(2)—the statutory definition in Be- gay contained a list of examples followed immediately by a residual clause. The latter structure more readily supports interpreting the general clause in light of the specifics, much like a statute to which the ejusdem canon would ap- ply. Moreover, the residual clause at issue in Begay called out for a limiting principle—what is a “serious potential risk of physical injury?" The breadth itself was a cue that

8 FISCHER v. UNITED STATES BARRETT, J., dissenting the interpreter should read back to find some limit. See id., at 142–143. Subsection (c)(2)'s “otherwise” clause, by con- trast, stands on its own. Postscript: Seven years after Begay was decided, we held ACCA's residual clause void for vagueness. Johnson v. United States, 576 U. S. 591, 597 (2015). So the clause is not only distinguishable, but also a poor model for statutory interpretation. 3 The Court argues that "there would have been scant rea- son for Congress to provide any specific examples” in (c)(1) if (c)(2) covered all forms of obstructive conduct. Ante, at 8. Conduct like destroying and concealing records "obstructs, influences, or impedes a[n] official proceeding,” so Congress could have enacted just (c)(2) and been done with it. On the Government's interpretation, the Court asserts, the second prohibition swallows the first. If (c)(1) has any function, it must be to cast light (and impose limits) on (c)(2). What the Court does not say is that its rewrite also elim- inates the need for (c)(1)'s examples. The Court's interpre- tation assumes that Congress used a convoluted, two-step approach to enact a prohibition on “impair[ing] the integ- rity or availability of records, documents, or other objects for use in an official proceeding." So why didn't Congress just say that? And if the Court is right about what (c)(2) means, why do we need the specific examples in (c)(1)? Those acts are already covered. The problem of (c)(2) sub- suming (c)(1) is therefore not unique to my theory. It bears emphasis, though, that the broad overlap makes sense, given the statute's backstory. When the Enron scan- dal occurred, Congress (along with the general public) was taken aback to discover that seemingly criminal conduct was actually not a federal crime. As it then existed, §1512 had a loophole: It imposed liability on those who persuaded others to destroy documents, but not on the people who

Cite as: 603 U. S. (2024) 9 BARRETT, J., dissenting themselves destroyed documents. Ante, at 9–10. Congress enacted §1512(c) to close this “Enron gap.” Subsection (c)(1) deals with the particular problem at hand-document de- struction. Subsection (c)(2) reflects Congress's desire to avoid future surprises: It is “a catchall for matters not spe- cifically contemplated-known unknowns." Republic of Iraq v. Beaty, 556 U. S. 848, 860 (2009). So contrary to the Court's suggestion, it would not be “pe- culiar" for (c)(2) to cover conduct “far beyond the document shredding and similar scenarios that prompted the legisla- tion in the first place." Ante, at 10. Enron exposed more than the need to prohibit evidence spoliation-it also ex- posed the need to close statutory gaps. And in any event, statutes often reach beyond the “principal evil” that ani- mated them. Oncale v. Sundowner Offshore Services, Inc., 523 U. S. 75, 79 (1998). That is not grounds for narrowing them, because “it is ultimately the provisions of our laws rather than the principal concerns of our legislators by which we are governed." Ibid. While the Court insists that (c)(1) limits (c)(2), it cannot seem to settle on the "common attribute" in the first subsec- tion that cabins the second. See Ali, 552 U. S., at 225. On one hand, the Court says that “(c)(2) makes it a crime to impair the availability or integrity of records, documents, or objects used in an official proceeding." Ante, at 8 (emphasis added). This “physical evidence” limitation tracks the Dis- trict Court's interpretation. See United States v. Miller, 589 F. Supp. 3d 60, 78 (DC 2022). On the other hand, the Court says that (c)(2) prohibits “impairing the availability or in- tegrity of other things used in an official proceeding," such as "witness testimony” or “intangible information." Ante, at 9. This broader “evidence impairment” theory resembles Judge Katsas's interpretation. 64 F. 4th 329, 363 (CADC 2023) (dissenting opinion).

10 10 FISCHER v. UNITED STATES BARRETT, J., dissenting Both formulations are problematic—and not only because both are atextual. The first, focused solely on physical items, would leave (c)(2) with almost no work to do. Sub- section (c)(1) already prohibits “alter[ing], destroy[ing], mu- tilat [ing], or conceal[ing]" documents, records, or objects. This essentially covers the waterfront of acts that impair the integrity or availability of objects. True, (c)(2) could also encompass "cover[ing] up, falsif[ying], or mak[ing] a false entry in” a record or document. See 18 U. S. C. §1519. But it seems “unlikely" that Congress used the “expansive” lan- guage of (c)(2) “to address such narrow concerns." 64 F. 4th, at 344. The somewhat amorphous “other things” limitation has the benefit of giving (c)(2) a wider berth, but it is un- clear how the Court landed on it. The term does not appear in (c)(1) or in §1512's surrounding subsections, which refer specifically to records, documents, objects, and testimony. The "other things” formulation comes from the Court, not Congress. The Court's uncertainty about the relevant “common at- tribute" is a tell that Congress did not intend to define (c)(2) by reference to (c)(1). Indeed, “[h]ad Congress intended to limit [§1512(c)(2)]'s reach" as the Court asserts, it "easily could have written” the catchall to say “otherwise impair the integrity or availability of records, documents, objects, or other things for use in an official proceeding." Ali, 552 U. S., at 227; see ante, at 8-9.2 It did not, and we should not pretend that it did. B The Court relies on statutory context to "confir[m] that 2 Indeed, Congress could have looked to 18 U. S. C. §1505 as a model. That statute makes it a crime to "willfully withhol[d], misrepresen[t], remov[e] from any place, concea[1], cove[r] up, destro[y], mutilat[e], alte[r], or by other means falsif[y] any documentary material, answers to written interrogatories, or oral testimony" with the intent to obstruct "any civil investigative demand.” §1505 (emphasis added).

Cite as: 603 U. S. (2024) 11 BARRETT, J., dissenting (c)(2) is limited by the scope of (c)(1)." Ante, at 10. As the Court sees it, interpreting (c) (2) according to its plain text would render other obstruction provisions, within §1512 and throughout Chapter 73, superfluous. Ante, at 10–12. The Court exaggerates. Subsection (c)(2) applies only to conduct that obstructs an “official proceeding." The Court highlights several provisions that cover obstruction of in- vestigations. See, e.g., 18 U. S. C. §§1510(a), 1511(a), 1516, 1517, 1518, 1519. The circuits have held that criminal in- vestigations do not qualify as “official proceedings." See, e.g., United States v. Ermoian, 752 F. 3d 1165, 1172 (CA9 2013); United States v. Ramos, 537 F. 3d 439, 463 (CA5 2008). Likewise, not every provision in §1512 relates to an official proceeding; instead, several target the obstruction of communications to judges and law enforcement about the commission of federal offenses. 18 U. S. C. §§1512(a)(1)(C), (a)(2)(C), (b)(3), (d)(1)(2). The Court responds by stressing that for purposes of §1512, "an official proceeding need not be pending or about to be instituted." §1512(f)(1); ante, at 13. Because obstruc- tion of investigations or communications could end up ob- structing the initiation of a future official proceeding, the Court reasons that (c)(2) may still swallow those other pro- visions. But we have previously construed federal obstruc- tion offenses similar to §1512(c) to require a tighter link be- tween the obstructive conduct and the relevant proceeding. Under the "nexus” requirement, the defendant's conduct must have a “relationship in time, causation, or logic” with the proceeding. Aguilar, 515 U. S., at 599 (adopting nexus requirement for §1503's omnibus clause). And the defend- ant must act in “contemplation” of a “particular official pro- ceeding." Arthur Andersen LLP v. United States, 544 U. S. 696, 708 (2005) (adopting nexus requirement for §1512(b)(2)). The circuits have unanimously applied this requirement to §1512(c). See United States v. Young, 916 F. 3d 368, 386 (CA4 2019) (collecting cases). This element

12 FISCHER v. UNITED STATES BARRETT, J., dissenting eliminates much of the overlap that the Court perceives be- tween (c)(2) and the provisions that do not require an “offi- cial proceeding.” Moreover, §§1512(a)(1)(A) and (d)(1) prohibit preventing the mere attendance of any person in an official proceeding. Preventing attendance will not always have the effect of ob- structing, influencing, or impeding the proceeding. And §1512(d)(1) makes it a crime to intentionally harass some- one and thereby dissuade her from testifying in an official proceeding. In contrast to (c)(2), this provision—which car- ries a significantly lower maximum penalty-does not re- quire a defendant to act “corruptly." This is not to deny that (c)(2)—if allowed its broad, ordi- nary meaning-overlaps with several offenses in Chapter 73. See ante, at 10-11. Even so, (c)(2) still leaves a healthy amount of work for other obstruction offenses. And besides, "substantial" overlap "is not uncommon in criminal stat- utes." Loughrin v. United States, 573 U. S. 351, 358, n. 4 (2014); see also Hubbard v. United States, 514 U. S. 695, 714, n. 14 (1995) (opinion of Stevens, J.). "The mere fact that two federal criminal statutes criminalize similar con- duct says little about the scope of either.” Pasquantino v. United States, 544 U. S. 349, 358, n. 4 (2005). That is espe- cially true here, because Congress enacted (c)(2) after it had already enacted other subsections of §1512, as well as ob- struction offenses like §§1503 and 1505. The redundancy argument would have more force if (c)(2) “render[ed] super- fluous an entire provision passed in proximity as part of the same Act." Yates v. United States, 574 U. S. 528, 543 (2015) (plurality opinion) (emphasis added). As it stands, the canon against surplusage does not provide any reason to ar- tificially narrow (c)(2)'s scope. In any event, the Court's formulation does not begin to cure the statutory overlap. Killing a person with the intent to prevent the production of a record in an official proceed- ing constitutes conduct that impairs the availability of a

Cite as: 603 U. S. (2024) 13 BARRETT, J., dissenting record for an official proceeding. 18 U. S. C. §1512(a)(1)(B). Using physical force against a person to influence testi- mony in an official proceeding counts as impairing the in- tegrity of "other things" used in an official proceeding. §1512(a)(2)(A). And impairing the availability or integrity of documents for use in an official proceeding will often “in- fluenc[e], obstruc[t], or imped[e] . . . the due administration of justice." §1503(a); see also §1515(a)(1)(A) (“official pro- ceeding"" includes “a proceeding before a judge or court of the United States"). Examples abound. See, e.g., §§1505, 1512(a)(1)(A), (a)(2)(B), (b)(1), (b)(2), (d)(1). “[T]he canon against surplusage merely favors that interpretation which avoids surplusage”—and on that score, the Court's inter- pretation fares no better than mine. Freeman v. Quicken Loans, Inc., 566 U. S. 624, 635 (2012). In fact, the broader statutory context works against the Court's interpretation. Congress did not select the verbs "obstruct," "influence,” and “impede” at random. Those words were already in §1503, which prohibits “corruptly or by threats or force, or by any threatening letter or commu- nication, influenc[ing], obstruct[ing], or imped[ing] . . . the due administration of justice." We have described this "Omnibus Clause"" as a "catchall," because it follows sev- eral specific proscriptions against coercive behavior toward jurors and court officers. Aguilar, 515 U. S., at 598. Courts have routinely declined to "rea[d] the omnibus clause” as limited to "acts similar in manner to those prescribed by the statute's specific language.” United States v. Howard, 569 F. 2d 1331, 1333, 1335 (CA5 1978) (collecting cases). And Justice Scalia agreed that ejusdem generis did not apply to limit the Omnibus Clause, “one of the several distinct and independent prohibitions contained in §1503 that share only the word 'Whoever,' which begins the statute, and the penalty provision which ends it." Aguilar, 515 U. S., at 615 (opinion concurring in part and dissenting in part). Section 1512(c) follows the very same pattern.

14 FISCHER v. UNITED STATES BARRETT, J., dissenting C The Court concludes with an appeal to consequences: Construing (c)(2) broadly would “expos[e] activists and lob- byists alike to decades in prison." Ante, at 14. This fear is overstated. To begin with, the Court ignores that (c)(2) requires proof that a defendant acted “corruptly.” The meaning of this term is unsettled, but all of its possible definitions limit the scope of liability. On one proposed interpretation, a defend- ant acts corruptly by “us[ing] unlawful means, or act[ing] with an unlawful purpose, or both."" United States v. Rob- ertson, 103 F. 4th 1, 8 (CADC 2023) (approving jury instruc- tions for (c)(2)). On another, a defendant acts "corruptly" if he “act[s] ‘with an intent to procure an unlawful benefit ei- ther for himself or for some other person."" 64 F. 4th, at 352 (Walker, J., concurring in part and concurring in judgment) (quoting Marinello, 584 U. S., at 21; alterations omitted). Under either, the “corruptly” element should screen out in- nocent activists and lobbyists who engage in lawful activity. And if not, those defendants can bring as-applied First Amendment challenges. The Court also emphasizes (c)(2)'s 20-year maximum penalty. Ante, at 14-15. But it simultaneously "glosses over the absence of any prescribed minimum." Yates, 574 U. S., at 569 (KAGAN, J., dissenting). “Congress presuma- bly enacts laws with high maximums and no minimums when it thinks the prohibited conduct may run the gamut from major to minor." Ibid. Indeed, given the breadth of its terms, (c) (2) naturally encompasses actions that range in severity. Congress presumably trusted District Courts to impose sentences commensurate with the defendant's particular conduct. * * * There is no getting around it: Section 1512(c)(2) is an ex- pansive statute. Yet Congress, not this Court, weighs the

Cite as: 603 U. S. (2024) 15 BARRETT, J., dissenting "pros and cons of whether a statute should sweep broadly or narrowly." United States v. Rodgers, 466 U. S. 475, 484 (1984). Once Congress has set the outer bounds of liability, the Executive Branch has the discretion to select particular cases to prosecute within those boundaries. By atextually narrowing §1512(c)(2), the Court has failed to respect the prerogatives of the political branches. Cf. ante, at 15. I re- spectfully dissent.

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• How to conclude an essay | Interactive example

How to Conclude an Essay | Interactive Example

Published on January 24, 2019 by Shona McCombes . Revised on July 23, 2023.

The conclusion is the final paragraph of your essay . A strong conclusion aims to:

• Tie together the essay’s main points
• Show why your argument matters
• Leave the reader with a strong impression

Your conclusion should give a sense of closure and completion to your argument, but also show what new questions or possibilities it has opened up.

This conclusion is taken from our annotated essay example , which discusses the history of the Braille system. Hover over each part to see why it’s effective.

Braille paved the way for dramatic cultural changes in the way blind people were treated and the opportunities available to them. Louis Braille’s innovation was to reimagine existing reading systems from a blind perspective, and the success of this invention required sighted teachers to adapt to their students’ reality instead of the other way around. In this sense, Braille helped drive broader social changes in the status of blindness. New accessibility tools provide practical advantages to those who need them, but they can also change the perspectives and attitudes of those who do not.

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Table of contents

Step 1: return to your thesis, step 2: review your main points, step 3: show why it matters, what shouldn’t go in the conclusion, more examples of essay conclusions, other interesting articles, frequently asked questions about writing an essay conclusion.

To begin your conclusion, signal that the essay is coming to an end by returning to your overall argument.

Don’t just repeat your thesis statement —instead, try to rephrase your argument in a way that shows how it has been developed since the introduction.

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Next, remind the reader of the main points that you used to support your argument.

Avoid simply summarizing each paragraph or repeating each point in order; try to bring your points together in a way that makes the connections between them clear. The conclusion is your final chance to show how all the paragraphs of your essay add up to a coherent whole.

To wrap up your conclusion, zoom out to a broader view of the topic and consider the implications of your argument. For example:

• Does it contribute a new understanding of your topic?
• Does it raise new questions for future study?
• Does it lead to practical suggestions or predictions?
• Can it be applied to different contexts?
• Can it be connected to a broader debate or theme?

Whatever your essay is about, the conclusion should aim to emphasize the significance of your argument, whether that’s within your academic subject or in the wider world.

Try to end with a strong, decisive sentence, leaving the reader with a lingering sense of interest in your topic.

The easiest way to improve your conclusion is to eliminate these common mistakes.

Don’t include new evidence

Any evidence or analysis that is essential to supporting your thesis statement should appear in the main body of the essay.

The conclusion might include minor pieces of new information—for example, a sentence or two discussing broader implications, or a quotation that nicely summarizes your central point. But it shouldn’t introduce any major new sources or ideas that need further explanation to understand.

Don’t use “concluding phrases”

Avoid using obvious stock phrases to tell the reader what you’re doing:

• “In conclusion…”
• “To sum up…”

These phrases aren’t forbidden, but they can make your writing sound weak. By returning to your main argument, it will quickly become clear that you are concluding the essay—you shouldn’t have to spell it out.

Don’t undermine your argument

Avoid using apologetic phrases that sound uncertain or confused:

• “This is just one approach among many.”
• “There are good arguments on both sides of this issue.”
• “There is no clear answer to this problem.”

Even if your essay has explored different points of view, your own position should be clear. There may be many possible approaches to the topic, but you want to leave the reader convinced that yours is the best one!

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• Argumentative
• Literary analysis

This conclusion is taken from an argumentative essay about the internet’s impact on education. It acknowledges the opposing arguments while taking a clear, decisive position.

The internet has had a major positive impact on the world of education; occasional pitfalls aside, its value is evident in numerous applications. The future of teaching lies in the possibilities the internet opens up for communication, research, and interactivity. As the popularity of distance learning shows, students value the flexibility and accessibility offered by digital education, and educators should fully embrace these advantages. The internet’s dangers, real and imaginary, have been documented exhaustively by skeptics, but the internet is here to stay; it is time to focus seriously on its potential for good.

This conclusion is taken from a short expository essay that explains the invention of the printing press and its effects on European society. It focuses on giving a clear, concise overview of what was covered in the essay.

The invention of the printing press was important not only in terms of its immediate cultural and economic effects, but also in terms of its major impact on politics and religion across Europe. In the century following the invention of the printing press, the relatively stationary intellectual atmosphere of the Middle Ages gave way to the social upheavals of the Reformation and the Renaissance. A single technological innovation had contributed to the total reshaping of the continent.

This conclusion is taken from a literary analysis essay about Mary Shelley’s Frankenstein . It summarizes what the essay’s analysis achieved and emphasizes its originality.

By tracing the depiction of Frankenstein through the novel’s three volumes, I have demonstrated how the narrative structure shifts our perception of the character. While the Frankenstein of the first volume is depicted as having innocent intentions, the second and third volumes—first in the creature’s accusatory voice, and then in his own voice—increasingly undermine him, causing him to appear alternately ridiculous and vindictive. Far from the one-dimensional villain he is often taken to be, the character of Frankenstein is compelling because of the dynamic narrative frame in which he is placed. In this frame, Frankenstein’s narrative self-presentation responds to the images of him we see from others’ perspectives. This conclusion sheds new light on the novel, foregrounding Shelley’s unique layering of narrative perspectives and its importance for the depiction of character.

If you want to know more about AI tools , college essays , or fallacies make sure to check out some of our other articles with explanations and examples or go directly to our tools!

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Your essay’s conclusion should contain:

• A rephrased version of your overall thesis
• A brief review of the key points you made in the main body
• An indication of why your argument matters

The conclusion may also reflect on the broader implications of your argument, showing how your ideas could applied to other contexts or debates.

For a stronger conclusion paragraph, avoid including:

• Important evidence or analysis that wasn’t mentioned in the main body
• Generic concluding phrases (e.g. “In conclusion…”)
• Weak statements that undermine your argument (e.g. “There are good points on both sides of this issue.”)

Your conclusion should leave the reader with a strong, decisive impression of your work.

The conclusion paragraph of an essay is usually shorter than the introduction . As a rule, it shouldn’t take up more than 10–15% of the text.

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McCombes, S. (2023, July 23). How to Conclude an Essay | Interactive Example. Scribbr. Retrieved June 24, 2024, from https://www.scribbr.com/academic-essay/conclusion/

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