Oregon State Bar Bulletin — OCTOBER 2009
The Legal Writer
Perfect Tenses:
The Timing of Verbs
By Suzanne E. Rowe

Verbs are the power brokers of sentences, conveying the action. Verbs vary in tense to show us when the action took place. While most of us are perfect in using the simplest verb tenses, we aren’t so unanimously fabulous with the perfect tenses. Here’s a review.

Simple Past, Present and Future
The simple verb tenses show when the action took place: in the past, in the present or in the future.

They walked to the office yesterday.

They walk to the office each day.

They will walk to the office tomorrow.

As shown in these examples, we typically form the past tense by adding –ed to words. So walk becomes walked. If the verb already ends in –e, we just add a –d. So file becomes filed. There are a slew of irregular verbs: take—took, ride—rode, see—saw, just to name a few. Those of us who grew up speaking English are lucky that we don’t have to memorize these; we know them automatically. Readers who struggle with past tense forms can find lists of irregular verbs online (and a dozen examples listed later in this article).

To form the future, we typically just add will to the verb. So walk becomes will walk. Pretty easy.

Present Perfect
Now comes the hard part: What if you want to show that action began in the past but is continuing? Or that its impact is still being felt now? To do that, you need a present perfect verb. Compare the meaning of these two sentences:

Rebecca clerked for the judge for two years.

Rebecca has clerked for the judge for two years.

In the first sentence, we assume that after the two-year clerkship, Rebecca found another job and the judge hired a new clerk. In the second sentence, we assume that Rebecca is still clerking for the judge, perhaps because the judge hires only permanent clerks.

Let’s turn to the second use of the present perfect. In one of the next two sentences, the impact of one verb from the past is still being felt in the part of the sentence happening currently.

Rebecca wrote excellent bench briefs, so the judge trusted her to draft his opinions.

Rebecca has written excellent bench briefs for the past two years, so the judge now trustsher to draft his opinions.

Did you catch the difference? In the first sentence, all of the action has been completed — the writing and the trusting — and Rebecca has moved on to a new job. In the second sentence, Rebecca is still working for the judge. Because of her continuing ability to write well, the judge trusts her to draft opinions.

Perfect Forms
Before considering the past and future perfect, let’s take a detour to examine what comprises the perfect tenses. (Don’t skip this section! I warned you that this verb stuff is hard!)

The perfect verb has two parts: some form of the auxiliary verb “to have” and the past participle. The present tense form of “to have” includes “has” and “have,” as in she has and we have. That’s easy enough.

Forming the past participle of regular verbs is easy, too. Just add –ed to the verb. Note that the past participle of a regular verb looks just like the past tense of the verb, as in the next two examples.

Past: I thanked my colleague for her help.

Present perfect: I have thanked my colleague for her help.

Forming the past participle of English’s many irregular verbs may be harsh if you didn’t grow up with a curmudgeon at home or in English class. The curmudgeon-blessed among us have lists of verbs moving mantra-like through our brains: drink-drank-drunk. Knowing the present, past, and past participle of verbs like lie-lay-lain and sing-sang-sung makes us feel smug in our deep knowledge of the English language.

For those of us who did not learn English at the knee of a grammar curmudgeon, a quick search on the Internet will produce the long list of irregular past participles in English. Here’s a partial list of the three forms, presentpastpast participle (repeat each as a mantra and you, too, can feel smug.):

begin began begun
choose chose chosen
drink drank drunk
go went gone
hide hid hidden
know knew known
ring rang rung
see saw seen
speak spoke spoken
swear swore sworn
take took taken
withdraw withdrew withdrawn

In a tight spot, just use the verb form that looks like the past tense. Often you’ll be right. We curmudgeons will correct you when you’re wrong.

Now, let’s continue to perfection in the past and future.

Past Perfect
The past perfect serves a slightly different function than the present perfect does. Remember that the present perfect shows some continuation from the past to the present. In contrast, the past perfect shows that two actions have been completed in the past, but one happened before the other. Try this example:

The detectives examined the evidence that they had gathered.

This sentence correctly uses past perfect to show that the detectives gathered the evidence first and then carefully examined it later, perhaps when they had more time or were working in a room with better lighting. Leaving out “had” would smudge the two tenses and leave the reader wondering when things happened. Did the detective examine the evidence at the scene or back at the station?

Note that we form the past perfect in the same way as the present perfect, with the auxiliary verb “to have” and the past participle. But in the past perfect, we use the past tense of “to have,” namely “had.”

Here’s another example that shows two different scenarios — and very different levels of diligence by one firm’s employees.

The law clerks began to work when the partner arrived.

The law clerks had begun to work when the partner arrived.

In the first example, the law clerks were chatting over coffee until the partner arrived; then they got to work. In the second example, the law clerks had been working diligently for a while before the partner showed up.

Future Perfect
Not surprisingly, the future perfect tense indicates an action that will be completed by some point in the future. This form uses the future tense of the auxiliary “will have” and the past participle. For example, I will have cleaned my office by Thanksgiving.


The Chicago Manual of Style: The Essential Guide for Writers, Editors, and Publishers (15th ed. 2003).

The Purdue Online Writing Lab, http://owl.english.purdue.edu/owl/resource/601/01

My English Teacher, http://www.myenglish teacher.net/irregular_verbs.html

Suzanne E. Rowe is an associate professor at the University of Oregon School of Law, where she directs the Legal Research and Writing Program. As the Luvaas Faculty Fellow for 2008-2010, she is grateful to the Luvaas Faculty Fellowship Endowment Fund for support of her articles in The Legal Writer.

An archive of  The Legal Writer articles is available here.

© 2009 Suzanne E. Rowe

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