The second oddity is that California is the only state that always precedes a citation to statute subsections with the word "subdivision" (abbreviated in some contexts to "subd."). The reason is that the Legislature often failed to leave gaps in the section numbering in the California codes for future expansion, and then occasionally resorted to the shortsighted technique of appending an alphabetical letter to a section number in order to insert a new section between two existing sections on similar subject matter. For example, the summary judgment statute in California is Section 437c of the Code of Civil Procedure. But alphabetical letters are traditionally used in the U.S. to designate "subsections" of statutes. To avoid confusion as to whether one is citing section 437c (that is, the section with number 437c) or 437(c) (subsection (c) of the section numbered 437), the "subdivision" prefix must be used when citing any subsection of "all" California statutes.