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I'm doing some homework. I am quoting from an administrative law decision. The hearing officer who wrote the decision quoted from a Supreme Court dissenting opinion, which quoted from a previous decision (Burlington School Committee v. Dept Ed., 471 U. S. 359 (1985)). The dissenting opinion was written with impeccable scholarly style, as you can imagine.

But the hearing officer was a little bit sloppy. He left out the Burlington citation. I want to add this, in brackets, for completeness. (Otherwise, the reader would wonder why there were quotation marks at that point in the text.) I know how to do this -- with brackets!

But there are already some brackets present. The person who put the original brackets there was Justice Breyer.

How do I distinguish between my brackets and Justice Breyer's? Or is it okay to mix apples and oranges and make no distinction between my brackets and his?

Here's what I've got (with my bracketed material in bold):

The practical significance of the Act's participatory rights and procedural protections may be seriously diminished if parents are unable to obtain reimbursement for the costs of their experts. In IDEA cases, experts are necessary…. [W]ithout cost reimbursement for prevailing experts, 'the child's right to a free appropriate public education, the parents' right to participate fully in developing a proper individualized education plan (IEP), and all the procedural safeguards would be less complete' [quoting from Burlington School Committee v. Dept Ed., 471 U. S. 359 (1985)]…[and] is a far cry from the level playing field that Congress envisioned.

In case you want to see the original publications:

The hearing decision is Case Number 16795, decided March 24, 2017, decided by Brad H. Rosken, Esq., which was published by the State of New York in the first of the 2017 zip files here (see 97507-20170324.pdf).
Justice Breyer's dissenting opinion is here.
The Burlington decision quoted by Justice Breyer is here.

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  • 1
    You could put it in a footnote.
    – Jim
    Feb 24 '20 at 13:53
  • I think there will always be ambiguity. For instance, the reader can't tell that [W] is from the original rather than your editing.
    – Barmar
    Feb 25 '20 at 1:38
  • @Jim - I'll accept that if you make it an answer, with Barmar's reasoning. Feb 25 '20 at 17:17

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