The Role of Notaries Public in the US

What does a US notary do_

Spanish lawyers soon discover that they have to explain to many of their English-speaking clients the role that Spanish notarios (or civil law/Latin notaries, in general) play in ensuring legal certainty in civil law systems, why notarios must intervene in many seemingly everyday transactions and, ultimately, why they charge what they do(!).

But the opposite is also true: I’m sometimes asked about the role of notaries in the US, and I recently found an excellent answer to that question in an article that I’m sharing in a link below. Published in the Colegio Notarial de Madrid’s journal El Notario del Siglo XXI, the article entitled “¿Qué es lo que hace un ‘notary public’?” was written by José Antonio Márquez González, Mexican notario and member of the International Union of Notaries (UINL). It explains in Spanish and in detail the work of US notaries, providing sample texts in English and an extensive bibliography in the footnotes. It’s available here:


Use of interesar in Legal Texts

legal words

Rather than “to manifest interest” as the term is sometimes rendered, in legal contexts interesar often has the meaning of solicitar (to request, to petition, to motion, etc.), especially when used in pleadings and other court documents. As defined in the DLE, “interesar may mean “solicitar o recabar de alguien, datos, noticias, resoluciones, etc.” Here are a few examples in which interesar denotes solicitar in the sense of “petitioning the court,” with possible English translations:

  • práctica de la prueba que interesábamos en nuestro escrito de querella (examination of evidence requested in our criminal complaint)
  • el Ministerio Fiscal interesó que se hiciera a los solicitantes audiencia (the prosecution moved that the applicants be granted a hearing)
  • se interesaba que se señalara nuevo día y hora para la vista (a motion to continue was filed, requesting a change of date and time for the hearing)
  • se presentó escrito por el que se interesaba el sobreseimiento de las actuaciones (a motion to dismiss was filed)
  • el demandante interesaba una indemnization por daños (the plaintiff filed for damages)

Terminology Sources: An Overview of English Law

uk parliament-2

The “In Brief” legal resource website is a must for translators, interpreters and legal professionals who need to acquire a working knowledge of the law of England and Wales in many of the major legal disciplines. It describes itself as a “growing legal resource providing information on a variety of legal issues” that “aims to be the largest source of legal material of its kind anywhere on the Internet.” This may appear to be somewhat of an exaggeration, but the information provided does indeed cover an extensive range of legal topics, including

  • Agricultural Law
  • Animal Law
  • Business Finance
  • Charity Law
  • Child Law
  • Civil Court
  • Claim Preparation
  • Clinical Negligence
  • Company Law
  • Consumer Law
  • Contract Law
  • Court Judgements
  • Court Proceedings
  • Discrimination Law
  • Divorce Law
  • Employees
  • Employers
  • Estate Law
  • Football Law
  • Human Rights
  • Immigration Law
  • Intellectual Property
  • Land Law
  • Legal System
  • Marriage Law
  • Media Law
  • Motoring Law
  • Offences
  • Personal Finance
  • Personal Injury
  • Police
  • Preparing For Trial
  • Property Law
  • Regulations
  • Sales Law
  • Sports Law
  • Types of Claim

Explore more here:

Spelling Differences (American vs. British English)



This post is not specifically on legal language, but several of my students of Legal English at the Universidad Carlos III asked me to summarize for them the basic differences between American and British spelling. I am including here part of a handout that I prepared for them in the event it may be of interest to a wider audience.

In researching this I came across an interesting article in the Daily Mail* that outlines the progression of the supposed acceptance of many American spellings in English worldwide. It maintains that as early as the 1880s English language publications began to prefer American spelling, which became even more popular after World War I. Charts appearing on seemit** actually show the years in which certain American terms supposedly surpassed the British (“gray” vs. “grey;” “flavor” vs. “flavour;” “liter” vs. “litre,” etc.)

Nevertheless, translators, legal professionals and students of legal English should be aware of what are still considered the preferred spellings on each side of the “Pond.” There may be some flux and leeway, and some may not view these as set-in-stone rules, but here is a minimal collection of US vs. UK spellings appearing on the Oxford Dictionaries website*** and in other sources:

Words ending in “-er”/“-re”
American Usage British Usage
center centre
fiber fibre
kilometer kilometre
liter litre
theater/theatre theatre
Words ending in “-or”/“-our”
American Usage British Usage
behavior behaviour
color colour
flavor flavour
humor humour
labor labour
neighbor neighbour
Words ending in “–ize”/“-ise”
American Usage British Usage
apologize apologize/apologise
emphasize emphasise
organize organize/organise
recognize recognize/recognise
Words ending in “-yze”/“-yse”
American Usage British Usage
analyze analyse
catalyze catalyse
paralyze paralyse
One “l” vs. two “ll”
American Usage (“l”) British Usage (“ll”)
travel travel
traveled travelled
traveling travelling
traveler traveller
fuel fuel
fueled feulled
fueling fuelling
counselor counsellor
American Usage (“ll”) British Usage (“l”)
enrollment enrolment
fulfill fulfil
installment instalment
skillful skilful
Words with “e” in American English and “ae”/”oe” in British
American Usage British Usage
leukemia leukaemia
maneuver manoeuver
estrogen oestrogen
pediatric paediatric
Nouns ending in “-ense”/“-ence”
American Usage British Usage
defense defence
license licence
offense offence
pretense pretence
Nouns ending with “-og”/“-ogue”
American Usage British Usage
analog/analogue analogue
catalog/catalogue catalogue
dialog/dialogue dialogue
American Usage British Usage
airplane aeroplane
check cheque
cozy cosy
curb kerb
draft draught/draft
gray grey
jail gaol
mold mould
plow plough
program programme

* Cheyenne MacDonald. “The future is gray for British English: How American Spellings are taking over the world with ‘flavor,’ ‘center’ and ‘defense’ becoming the norm.” Daily Mail, July 27, 2016.

** “The Decline of British English, Visualized” (author: oakstone)


An Historical Introduction to Legal English

ancient cloudy daylight england

The personal website of the American medievalist and Latin scholar Daniel Williman contains an outstanding work on legal English: “Legal Terminology: An Historical Introduction to the Technical Language of the Law.” For each area of law Professor Williman provides historical background, followed by related terminology and definitions. First published in book form by the University of Toronto Press in 1986, a glance at the Table of Contents of this work shows just how complete this overview is:

  1. Language and European History
  2. Legal History and Legal Terminology
  3. Litigation, Pleading and Trial
  4. History I: Roman Civil Law
  5. Contracts and Debts
  6. Judgement and Enforcement
  7. History II: Canon Law and Jus Commune
  8. Wills and Estates
  9. Penal Law
  10. History III: Germanic and French Custom, Feudal Law, Law French
  11. Domestic Relations
  12. Crime
  13. Documents, Instruments, and the Record
  14. History IV: English Common Law
  15. Real Property
  16. Criminal Procedure
  17. Equity
  18. Commercial Law
  19. History V: North American Reception of European Law
  20. Logical Argument and Evidence
  21. Torts
  22. Corporation, Partnership, and Securities
  23. Sovereignty and Conflict of Laws

It is possible to browse the work by chapters using the links above, or view it in its entirety (with its Preface, Introduction, References and Index to Latin maxims) here:




Understanding fe pública

ExpressingCivil LawConcepts

Fe pública is defined as la facultad con la que están investidos determinados agentes para certificar que los hechos que les constan son verdaderos y auténticos.* I have seen fe pública translated literally as “public faith” and “public trust, renderings that admittedly don’t reflect the meaning of the expression, and as “affidavit,” a term denoting a sworn statement (declaración jurada) that may be made by any individual and not necessarily by the agents authorized to do so as in the definition above.

The act itself (el hecho de “dar fe”) has sometimes been rendered as “notarial attestation,” a possible translation if the certifying authority (fedatario público) in question is a notary public. Indeed, although most often associated with notaries, fedatario público refers to anyone authorized to ejercer la fe pública (i.e., to issue documents certifying a given event as true and authentic). Thus there is fe pública notarial, fe pública judicial, fe pública registral, fe pública administrativa, etc., and fedatarios públicos include not only notaries, but also court clerks, registrars and certain authorized civil servants. Moreover, if certification is required in a foreign country, the local Spanish consul ejerce la fe pública in his jurisdiction.

*Diccionario del español jurídico de la RAE