Anthony T. Kronman The traditional use of the male pronoun "he" to refer to persons of both sexes is a practice that has in recent years become a subject of controversy. Writers have adopted different strategies to deal with the problems they believe this practice presents. Some, for example, never use "he" alone, but always substitute "he or she" instead, and others alternate the use of "he" and "she," either randomly or in some regular way. The first of these strategies I find cumbersome and the second has always seemed to me (as a reader) more distracting than enlightening or refreshing. I have therefore elected to follow a modified version of the traditional practice, using "he" alone most of the time and "he or she" occasionally. Whatever its vices, this approach at least possesses the virtues of clarity and economy. When I use the pronoun "he" and its variant forms in a general or impersonal sense, I mean, of course, to refer to men and women alike.

(Anthony T. Kronman, "Living in the Law," The University of Chicago Law Review 54 [summer 1987]: 835-76, at 835 n. †)