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On the Apostrophe

Garner's The Elements of Legal Style, Rule 2.6 (Oxford, 1991)(emphasis in original) states the following:

2.6 Form Singular Possessives by Adding 's to the Singular Form of the Noun

The rules holds true regardless of how the word ends: thus, witness's, Jones's, Congress's, and testatrix's. There are three exceptions to the rule. First, the word its is possessive, it's being the contraction for it is. Second, your and hers, which are absolute possessives, take no apostrophe. Third, biblical and classical names that end with a -zes, or -eez sound take only the apostrophe. Thus,

Jesus' Moses' Aristophanes' Socrates'

If the possessive form seems awkward to you, rephrase: the laws of Moses instead of Moses' laws, the action of Congress or the congressional action instead of Congress's action.

Given the treatment of Customs as a singular entity, I take it from Garner (my go-to grammar guy) that the CAFC was correct as a matter of formal grammar. Customs's will be my preferred usage henceforth and I am a little embarrassed that I had floated toward treating Customs as a plural noun, which would justify my use of the naked apostrophe. But, that still leaves open the question of Customs's own institutional preference and whether there is any reason for it.

Full post as published by Customs Law on September 30, 2009 (boomark / email).