Definition
In law, a scroll has two distinct meanings:
1. A pen-made mark or flourish, typically surrounding the letters "L.S." (locus sigilli, meaning "place of the seal") or the word "Seal," intended to substitute for a wax or impressed seal on a deed or other written instrument. In jurisdictions that recognize it, a scroll affixed in the appropriate place on an instrument, with evident intent to serve as a seal, carries the legal effect of a formal seal.
2. A roll of parchment or paper containing writing — a document in rolled form. In older legal contexts, court records, pleadings, and enrolled instruments were literally scrolls in this physical sense.
The first meaning is the one with operative legal significance in American law. The second is primarily descriptive and historical, though it appears in statutes and older court records referring to enrolled documents.
Common Language
Modern common usage (Wiktionary): A roll of paper or parchment containing writing; an ornament formed of undulations or spirals suggestive of plant form; a mark or flourish added to a person's signature, intended to represent a seal.
Historical common usage (Webster's 1913): A roll of paper or parchment; a writing formed into a roll; a schedule or list; an ornamental spiral form; a mark or flourish added to a person's signature.
The common meaning captures the physical object accurately but undersells the legal stakes. In law, the scroll-as-seal is not merely decorative — in jurisdictions that treat it as a valid seal substitute, it determines whether an instrument is a sealed instrument, which historically affected the applicable statute of limitations, the availability of certain common law remedies, and whether consideration was required to enforce the document. A researcher who treats "scroll" as simply meaning a roll of paper will miss this operative dimension entirely.
Common Confusion
Scroll and seal are frequently conflated in historical instruments. A seal, strictly speaking, was a wax impression or embossed mark authenticating a document. A scroll is a pen-drawn substitute. The legal consequences could be identical — but only in jurisdictions that affirmatively recognized scroll seals. In jurisdictions that did not, an instrument signed with a scroll where a seal was required was a defective instrument. Black's and Bouvier both treat the scroll as a seal substitute rather than a seal proper, and researchers should be alert to whether a given jurisdiction or instrument treats them as equivalent.
Why It Matters in Research
The central research issue with scroll is jurisdictional variation in its validity as a seal substitute. American states diverged sharply on whether a pen-and-ink scroll could replace a wax seal on deeds and other instruments. Bouvier notes that Mississippi and Florida recognized the scroll as having seal effect when the instrument's body, the scroll itself, or its placement made the intent clear. Other states rejected this entirely. This matters when dating and interpreting historical conveyancing documents: the presence or absence of "L.S." with a scroll flourish signals whether the drafter believed the instrument was sealed, but whether that belief was legally correct depends on the forum.
For corpus researchers working with pre-20th century deeds, contracts, and instruments, the scroll notation appears constantly. Understanding that it is a seal substitute — not just a decorative mark — is essential to correctly characterizing those instruments. Sealed instruments carried longer statutes of limitations at common law (typically twenty years versus six for simple contracts), could not be varied by parol evidence as easily, and in equity were treated differently from unsealed obligations.
The physical scroll meaning surfaces in research involving enrolled bills, court rolls, and parliamentary records. Medieval and early modern legal records were literally rolled parchments — the "Close Rolls," "Patent Rolls," and similar chancery records take their names from their physical form. Researchers using those materials need both meanings active.
WHY HISTORICAL SOURCES DIVERGE: Anderson's is the most precise of the shelf sources on the scroll-as-seal, noting that its form could be a circle, a scalloped curve, or even brackets — the form mattered less than the evident intent. Black's (both editions) gives the functional definition without that nuance. Bouvier is the most practically useful, citing treatise support and identifying specific states where the rule was established.
Historical Dictionary Support
All four shelf sources agree on the core definition: a scroll is a pen-made mark intended to substitute for a seal. There is no meaningful disagreement on this point.
Anderson adds useful granularity about what physical forms qualify — a scroll need not be an elaborate flourish; brackets written opposite a signature can suffice if intent is clear. This is important for reading historical instruments where the mark at "L.S." may be minimal.
Bouvier is the only shelf source that cites authority directly and names specific jurisdictions, making it the most useful starting point for a researcher trying to establish the scroll's legal effect in a particular state. His citation to Mitchell on Real Estate and Conveyancing points toward the treatise literature on this question.
Black's second edition appends a curious entry for "Scroop's Inn" immediately following the scroll definition — an obsolete law society in London, also called "Serjeants' Place." This proximity appears to be purely alphabetical and has no substantive connection to the legal meaning of scroll.
None of the shelf sources address the scroll in the context of digital or electronic documents, where the term has acquired an entirely unrelated technological meaning (scrolling through content on a screen). That modern usage is irrelevant to legal research but may generate noise in general-purpose searches.
Jurisdictional Note
Recognition of a scroll as a valid seal substitute was never uniform across American jurisdictions. Some states by statute abolished the distinction between sealed and unsealed instruments entirely, rendering the question moot. Others maintained the distinction but required a proper impressed or embossed seal. Researchers working with instruments from specific states should verify the governing rule at the time the instrument was executed, not merely the modern rule.