CHAPTER 8

Legal Citation

PART I STUDY OUTLINE

I. INTRODUCTION
A. In General
Whenever a reference is made in legal writing to the law (primary authority) or to a non-law source
upon which a court may rely (secondary authority), you must identify the source of the reference.
This reference is called a citation. The writer serves no purpose by referring a reader to a source of
information and incorrectly identifying the location of the source. There are several additional
reasons why it is important that your citations be correct:
■ A citation that is incorrect in form or content sends the message that the drafter is
either not careful or lacks education.
■ Errors in documents submitted to a court may cause the judge to question the
competence of the attorney and the quality and content of the research and analysis.
■ Opposing counsel may question the ability of the attorney to mount an effective
opposition and be less inclined to settle a case.
■ The writer’s research and analysis skills may become suspect if research sources are
not properly presented. Professional reputation is often determined by the quality of
one’s work product.

B. The Bluebook and the ALWD Citation Manual

The main guide and source of authority on legal citations for the past 75 years has been The
Bluebook: A Uniform System of Citation (Bluebook). Most states have adopted at least some
citation rules that differ from the Bluebook. Therefore it is necessary to check the state rules
whenever preparing a document to be submitted to a court. As an alternative to the Bluebook, the
Association of Legal Writing Directors created the ALWD Citation Manual: A Professional
System of Citation (ALWD).

II. PRIMARY AUTHORITY

Note that although most of the citation conventions are the same in both manuals, there are
differences between the Bluebook and the ALWD Citation Manual. Do not assume that you can
substitute one for the other. If the citation rules of the jurisdiction where you are filing a brief or
other court document requires the use of the Bluebook, then you must cite according to the
Bluebook rules.
A. Case Law—Bluebook R-10, B-2, B-5; ALWD-12

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Citations to federal and state cases are similar in form.

1. Citation Components—Bluebook R-10.1; ALWD-12.1

The components of a case citation are as follows:
1. Case name
2. Reporter in which the case is published (volume number, abbreviation of the reporter,
and page number on which the case begins)
3. Pinpoint page, if the citation is to a specific page
4. Parallel (unofficial) publication, if any (volume number, abbreviation of the
publication, and page number on which the case begins)
5. Abbreviation for the court issuing the opinion unless the issuing court is included in
the reporter abbreviation
6. Year of the decision in parentheses
7. Subsequent history of the case, if any

2. Case Names—Bluebook R-10.2; ALWD-12.2

a. Individual names. Cite the last names of the individuals, not the first name.
b. Organization and business names. Include an organization’s full name. When a
business has more than one legal designation (e.g., Co., Ltd. Corp., or Inc.), use the
first designation and omit the others.
c. Abbreviations. The abbreviations used in party names are presented in Table T.6 of
the Bluebook and in Appendix 3 of the ALWD.
d. Multiple parties. When there are multiple plaintiffs or defendants, include only the
first party on each side of the case. Do not use et al. or et ux. to indicate additional
parties.
e. Consolidated cases. When a case consists of more than one case consolidated
together, list only the first case.
f. United States. When the United States is a party, both the Bluebook and the ALWD
state that America should be omitted. The Bluebook requires that United States be
spelled out. The ALWD states that it should be abbreviated.
g. State or commonwealth. When citing a decision of a court of your state in which the
state or commonwealth is a party, refer only to the state, commonwealth, or people.
h. Geographic terms. Include in the citation only the first geographic location in a
party’s name.

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 i. Procedural phrases—in re, ex parte, and ex rel. In re refers to an action that does not
involve adversarial parties, but something such as an estate. Ex parte refers to an
action on behalf of one party without contest by the other side, such as a divorce in
which one party does not participate. Ex rel. refers to an action by one person on
behalf of another, such as a parent on behalf of a child.
j. The. Do not include The in a citation when it is the first word of a party name.
k. Property. When property is a party, such as when the government is seizing property,
include only the first-listed piece of property.
l. Punctuation. The case name is followed by a comma (then the reporter information);
the comma is not italicized or underscored.
m. Citations as part of a sentence. See section IV.D.2.f in the chapter.

3. Volume, Reporter, and Page—Bluebook R-10.3; ALWD-12.3 to ALWD-12.5

Following the case name in a citation is the reference to the reporter in which the case is printed.
This reference includes the volume number of the reporter and the page on which the case
begins. The volume number precedes the abbreviation for the reporter, followed by the page
number of the case.
a. Abbreviations. Always consult Bluebook Table T.1 or ALWD Chart 12.1 and
Appendix 2.
b. Spacing. Refer to the general rules governing spacing presented in section IV.D.2 in
the chapter.
c. United States Supreme Court. Unless required by local rule, citation to decisions of
the United States Supreme Court should be to the official reporter only, the United
States Reports. A parallel citation to another reporter should not be included.
d. United States Court of Appeals. Decisions to the United States Court of Appeals are
cited to the Federal Reporter.
e. United States District Courts. Decisions to the United States District Courts are cited
to the Federal Supplement.
f. State court and parallel citations. The format and abbreviations for citing state court
decisions are presented in Table T.1 of the Bluebook and in ALWD Appendix 1. The
general rule for state court decisions is to cite to the relevant regional reporter.
g. Page numbers. The page number on which the case begins follows the reporter
abbreviation. When the reference is to a specific page within the case, the reference to
the specific page (pinpoint citation) follows the initial page reference.
Some of the West reporters, such as the Supreme Court Reports, include throughout
the text of reported cases cross-references to the pages in the official reporter. This
cross-reference system is called star paging.
h. Cases not yet reported—slip opinions. A case may be unreported or not yet published
in a reporter and may be available only as a separate slip opinion or in loose-leaf
form.

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4. Date and Court Abbreviation—Bluebook R-10.4, R-10.5; ALWD-12.5,
ALWD-12.6
In parentheses following the reporter and page citation are the court abbreviation (if necessary)
and the date on which the case was decided. When the decision is by the United States Supreme
Court or highest court of a state, you do not have to insert the court abbreviation.

5. Subsequent History—Bluebook R-10.7; ALWD-12.8

The Bluebook and the ALWD state that the subsequent history should be included in the citation
unless it refers to the history on remand, a denial of rehearing, or a denial of certiorari or similar
discretionary appeals (where the cited case is more than two years old).

6. Prior History—Bluebook R-10.7; ALWD-12.9

The prior history of a case is not required and should be included in a citation only when it is
significant to a point presented in your writing. Place the prior history after the full citation.

7. Parenthetical Information—Concurring, Dissenting, and Plurality Opinion—

Bluebook R-10.6; ALWD-12.11
If the reference in your writing is to a part of an opinion other than the majority opinion, you
must so indicate in a parenthetical following the full citation.

8. Short Citation Format—Bluebook B-5.2; ALWD-12.21

Once a case has been cited in full, several short citation formats may be used depending on the
situation.

9. Neutral/Public Domain Citations—Bluebook R-10.3.3; ALWD-12.16

Increasingly, court decisions are available through court web sites and other sources, such as
public domain citations (also referred to as neutral or vendor neutral citations).

10. Cases—Electronic Sources

See section IV.M in the chapter for citations to electronic sources.

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B. Constitutions—Bluebook R-11; ALWD-13
Constitutions usually are composed of articles and amendments. According to the Bluebook, the
citation form for a constitution consists of the abbreviated name of the constitution, the article or
amendment number, and the section number. The ALWD requires the abbreviated name of the
constitution and a pinpoint reference (the article or amendment number and the section number).

C. Statutory Law—Bluebook R-12, B-6; ALWD-14

Statutes may be cited to the official or unofficial code, session law, or secondary sources. The
preference is to cite to the official code.

1. General Rules When Citing Statutes

The following rules apply when citing both federal and state statutes:
a. Main text and supplements. When the cited material is taken from the main text, the
year of the volume of the text is placed in parentheses at the end of the citation (the year
the volume was published, which usually appears on the spine of the volume). When
the cited material appears only in the supplement, you must so indicate in parentheses
with the date. When the cited material is taken from the main text and the supplement,
it must be indicated with the date.
b. Section symbol (§) and multiple sections. The section symbol (§) is used to indicate a
section of a statute.
c. Name of act. Although it is not required, the name of the act may be included in the
citation.

2. Federal Statutes—Bluebook R-12; ALWD-14.2

The federal statutes of general public interest are printed in three separate publications:
● United States Code (USC)—the official code
● United States Code Annotated (USCA)—Thomson West
● United States Code Service (USCS)—LexisNexis

The citation format for federal statutes is composed of the following elements:
1. Title number
2. Code abbreviation
3. Section symbol (§)
4. Section number
5. Publisher in parentheses when it is a commercial publication
6. Year of the publication or supplement (year the volume was published, which usually
appears on the spine of the volume) in parentheses
3. Short Citation Format State and Federal Statutes—Bluebook R-12.9; ALWD-14.5

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When the use of id. is appropriate (see section IV.I in the chapter), it is the preferred short
citation format.

4. State Statutes—Bluebook R-12; ALWD-14.4

The citation form for state statutes varies from state to state. The citation format for state statutes
usually includes the following elements:
1. Name of the code
2. Section symbol (§)
3. Chapter/title/section number
4. Publisher in parentheses when it is a commercial publication
5. Year of the publication or supplement (year the volume was published, which usually
appears on the spine of the volume) in parentheses

5. Session Laws—Bluebook R-12.4; ALWD-14.6 to ALWD-14.8

When a citation is not available in the official or unofficial codes, it is appropriate to cite to the
session law. The basic elements of a federal session law citation are:
1. Name or title of the act (optional). In the ALWD example, the name/title is italicized.
In the Bluebook Quick Reference examples, the name/title is neither italicized nor
underscored.
2. Law abbreviation and number
3. Pinpoint reference when citing a specific section
4. Volume, statute, and initial page number
5. Pinpoint page reference when referring to a specific page
6. Date (year in parentheses) of the cited volume of the Statutes at Large

D. Rules of Evidence and Procedure—Bluebook R-12.8.3; ALWD-17

The Bluebook rule governing citations to evidentiary and procedural rules differs from the
ALWD rule.

E. Administrative Law—Bluebook R-14; ALWD-19

The components of citations to administrative rules or regulations are as follows:

1. Title (topic or agency) number in the code publication
2. Abbreviated name of the publication (e.g., Code of Federal Regulations or CFR;
Federal Register or Fed. Reg.)
3. Section number or page number of the rule or regulation
4. Year of publication

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III. SECONDARY AUTHORITY
A. Annotated Law Reports—Bluebook R-16.6.5; ALWD-24

1. Full Citation Format

The components of an ALR citation are:
1. Full name of the author
2. The word annotation (Note: The ALWD omits the use of annotation following the
author name.)
3. Title (italicized or underscored)
4. Volume number
5. Abbreviated name of the publication
6. Page number on which the annotation begins (followed by the pinpoint page when a
specific page is referred to, e.g., 852, 860)
7. Year of publication

2. Short Citation Format

Use id. when appropriate (see section IV.I.1 in the chapter). When id. is not appropriate, include
the author’s last name, volume number, ALR series, at, and the pinpoint reference.

B. Legal Dictionary—Bluebook R-15.7; ALWD-25

1. Full Citation Format

A legal dictionary citation should include the following:
1. Author (if any)
2. Full name of the dictionary (underscored or italicized)
3. Page containing the definition (no comma after the name of the dictionary and the
page)
4. Editor (only required in the ALWD format)—begin parenthesis
5. Edition
6. Publisher (only required in the ALWD format)
7. Year of publication—end parenthesis

2. Short Citation Format

Use id. when appropriate (see section IV.I.1 in the chapter). When id. is not appropriate, repeat
the name and the page number.

C. Legal Encyclopedia—Bluebook R-15.7; ALWD-26

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1. Full Citation Format
A full citation to a legal encyclopedia should contain the following:
1. Volume number of the encyclopedia
2. Abbreviated name of the encyclopedia, usually either Am. Jur. 2d or C.J.S. (no
underscore or italics)
3. Title or topic name (italicized or underscored)
4. Section symbol (§) and section number within the article
5. Year of publication in parentheses

2. Short Citation Form

Use id. when appropriate (see section IV.I.1 in the chapter). When id. is not appropriate, repeat
the full citation without the date.

D. Periodicals—Law Review/Journal Citations—Bluebook R-16; ALWD-23

1. Full Citation Format

Following are the components of a law review, journal, or another periodical citation:
1. Full name of the author
2. Title of the article (italicized or underscored)
3. Volume number
4. Abbreviated title of the periodical
5. Page number on which the article begins (followed by the pinpoint page when a
specific page is referred to, e.g., 159, 165)
6. Year of publication in parentheses

2. Short Citation Form

Use id. when appropriate (see section IV.I.1 in the chapter). When id. is not appropriate, include
the author’s last name, the volume number, the periodical abbreviation, at, and the pinpoint
reference.

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E. Restatements—Bluebook R-12.85; ALWD-27

1. Full Citation Format

A citation to a Restatement should include the following:
1. Full name and edition of the Restatement (In the ALWD, the full name and edition is
in italics or underscored, including a subtitle when the reference is to a subtitle.)
2. Section symbol (§) and number of the Restatement
3. Year of publication in parentheses

2. Short Citation Format

Use id. when appropriate (see section IV.I.1 in the chapter). Otherwise, repeat the full citation
without the date.

F. Treatises/Books—Bluebook R-15; ALWD-22

1. Full Citation Format

Treatise and book citations should include the following:
1. Volume number when there is more than one volume
2. Full name of the author or editor when a name is given
3. Full title of the publication as it appears on the title page (italicized or underscored)
4. Number of the section, paragraph, or page when you are referring to a specific
number, paragraph, or page
5. Editor when there is one, the edition or series number of the book when it is not the
first edition, and the publisher (The Bluebook does not require the inclusion of the
publisher.)—begin parenthesis
6. Year of publication—end parenthesis

2. Short Citation Format

Use id. when appropriate (see section IV.I.1 in the chapter). When id. is not appropriate, include
the author’s last name, the title, at, and the pinpoint reference.

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IV. GENERAL RULES OF CITATION
A. Typeface—Bluebook R-2, B2; ALWD-1.1

The Bluebook R-2 requires different typeface conventions and the use of large and small capital
letters for citations in law reviews and other writings such as books. Bluepages B-2 covers the
use of italics/underscores in court documents and legal memoranda. ALWD-1.1 does not
distinguish between types of documents and states that ordinary type and italics or underscores
should be used in all legal writing.

B. Italics and Underscores—Bluebook B-2; ALWD-1.3

The following items should be italicized or underscored:
1. Case names
2. Titles of publications and most documents
3. Introductory signals, such as See and Contra
4. Internal cross-references and short forms, such as supra
5. Phrases indicating subsequent or prior history, such as aff’d and rev’d
6. Words or phrases introducing related authority, such as available at
7. Names of internet sites
8. Words used for emphasis, words italicized in the matter quoted, and foreign words
that are not common

C. Citation Placement in Sentences and Clauses—Bluebook B-2; ALWD-43.1

Citations are placed in legal documents by including them as separate citation sentences or
clauses or by incorporating them within a sentence.

1. Citation Sentence
When a statement about the law is a complete sentence, the citation immediately follows the
statement as a separate sentence that begins with a capital letter and ends with a period.

2. Citation Clause
When the citation supports only part of a sentence, the citation is placed as a clause immediately
after the statement it supports and is set off by commas.

3. Embedded Citations
When the authority is mentioned in the sentence, the citation may be incorporated within the
sentence.

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D. Abbreviations—Bluebook R-6, Tables T.5 to T.16, B-T.1, B-T.2; ALWD-2,
Appendix 3 to Appendix 5

1. In General
Various terms and sources, such as court names, legal periodicals, and case names, are
abbreviated in legal citations. The lists of abbreviations are included in the Bluebook tables and
the ALWD appendices referenced at the beginning of this subsection.

2. Spacing
In the Bluebook section, “Typical Legal Citations Analyzed” (pages 5–9), dots (
) are inserted in
the example to indicate a single space in the citation. In the ALWD, a green triangle (▲)
indicates a single space. Following is a summary of the rules governing spacing:
a. Single capital letters and ordinals. Do not place a space between single capital letters
or single capital letters and an ordinal.
b. Single capital letters and non-single capital letters. When an abbreviation includes
one or more capital letters and an abbreviation that does not include a single capital
letter, include a space between the single capital letter and the other abbreviation.
c. Abbreviated and non-abbreviated words. When an abbreviated word is combined
with a non-abbreviated word, place a space on each side of the non-abbreviated word.
d. Legal periodicals. In a legal periodical, use a space to separate the institutional or
geographic abbreviation from the other parts of the abbreviation.
e. Section symbol (§), paragraph symbol (¶), and ampersand (&). Place a space after
each of these symbols.
f. Authorities included in the text of a sentence. The name of an authority is not
abbreviated when it is incorporated in a sentence.

E. Capitalization—Bluebook R-8, B-10.6; ALWD-3

1. General Rule
In a heading, title, or subtitle, capitalize the initial letter of the first word; the first word following
a colon or dash; and all other words except articles, prepositions, and conjunctions.

2. Court and Party Designations

Bluepages B-10.6 states that in addition to capitalizing the word Court when referring to a
specific court such as the California Supreme Court; also capitalize Court when the court
receiving the document is referred to in the document. Bluepages B-10.6 also states that the party
designations (Plaintiff, Defendant, Appellant, etc.) should be capitalized when referring to the
parties in a matter before the court.
3. Specific Words
Rule 8 of the Bluebook includes a page-and-a-half list of specific words and rules governing
capitalization.

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4. All Other Capitalizations
Both manuals refer to the U.S. Government Printing Office Style Manual for the capitalization of
other words. The ALWD also refers to The Chicago Manual of Style.

F. Quotations—Bluebook R-5; ALWD-47 to ALWD-49

Use quotations for emphasis. Use quotes primarily for statutory language, the law or legal
principle presented by a court, or key portions of a court’s reasoning.

1. Quotation Marks
Quotations of fewer than 50 words should be placed in quotation marks (“ ”); the quotations are
not indented. The citation usually is placed after the sentence that contains the quotation. Place
periods and commas inside the quotation marks. Other punctuation, such as semicolons, colons,
question marks, and exclamation points, are placed outside the quotation marks unless they are a
part of the quotation.

2. Indented Quotations
Quotations of 50 words or more (called block quotations) are set off from the rest of the text by a
five-space indention (one tab) from the left and right margins and are single spaced.

3. Quote within a Quote

Enclose quotations within a block quotation in double quotation marks (“ ”).

4. Citing a Quote within a Quote

When the source of a quote within a quote is included within the quotation, do not repeat it in the
citation.

5. Altering Quotations
The reader must be alerted to any changes made to a quotation.

6. Omitting Words or Citations

When you are omitting one or more words, the following rules apply:
a. Use an ellipsis (…) to indicate the omission of material from the middle of a
quotation. To indicate the omission of words at the end of a quotation, use an ellipsis
and the final punctuation of the quote. Do not use an ellipsis to indicate the omission
of words at the beginning of a quotation when the quotation is part of a sentence.
b. Indicate the omission of a citation or footnote in a parenthetical.
7. Paragraph Structure
When a quotation of fewer than 50 words is the first sentence of a paragraph from the quoted
text, the paragraph is enclosed in quotation marks but is not indented. When the quotation is 50
words or more (a block quotation) and the quotation begins with the first sentence of a paragraph
from the quoted text, indent a second tab on the left side of the block quotation.

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G. Page Numbers (Pinpoint Citations)—Bluebook R-3.3, R-3.4, R-3.5; ALWD-5.2,
ALWD-5.3, ALWD-5.4
When quoting material from a source, include a reference to the exact page or location of the
information. That is referred to as a pinpoint cite or a jump citation.

H. String Citations—Bluebook R-1.1, R-1.2; ALWD-43.3(a)

When a proposition is supported by more than one authority in a citation clause or sentence, the
citation is referred to as a string citation. Use a colon to separate each authority cited. The use of
string citations in court documents and legal memoranda is generally disfavored, but their use is
not prohibited.

I. Short Citation Forms (Id., Supra, and Hereinafter)—Bluebook R-4, B-5.2, B-6.2,
B-8.2, B-9.2, B-10.5; ALWD-11.2 to ALWD-11.4
Once the full citation to an authority is presented in a document, subsequent citations to the
authority may be shortened. Those shortened citations usually are referred to as short citations or
short form citations. Short citations are used primarily because they save space and are less
disruptive to the flow of the text.

1. Id as a Short Citation
The term id. means “the same” and is used the same way ibid is used. You use id., not ibid., in
legal writing. The use of id. indicates that the source of the statement is the preceding citation.
Id. may be used for any legal authority except internal cross-references.

2. Supra as a Short Citation

The term supra as a short citation means “above” and is used to refer to a reference source that
was previously fully cited in a document. It cannot be used in place of id. In other words, supra
is not used when referring to an immediately preceding cited source. It is used to refer to a
previously cited source in a document when there have been other intervening cited sources.
Supra cannot be used to refer to cases, statutes, session laws, ordinances, legislative materials
(other than hearings), constitutions, and administrative regulations.

3. Hereinafter as a Short Citation

The term hereinafter may be used in certain circumstances to shorten a long title that is
cumbersome to cite repeatedly, such as when the source has no author and the title is long.

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J. Internal Cross-References (Supra and Infra)—Bluebook R-3.5; ALWD-10
Often, especially when a document is long or includes many footnotes, you will want to refer the
reader to source material on a specific page, section, or footnote of the document. For that
purpose, supra is used to refer to material that appears earlier in the document and infra is used
to refer to material that appears later.

K. Signals—Bluebook R-1.2 to R-1.5; ALWD-44 to ALWD-46

Signals are terms or words used to indicate the manner in which the cited authority supports or
contradicts the text.

1. Types of Signals
Following is a list of citation signals:
E.g.—Indicates that the cited authority is representative of (or an example of) many other
authorities that stand for the same proposition. It may be used with other signals, such as
see e.g. and but see, e.g.
See—Is used to indicate that the cited authority clearly supports a proposition but does
not directly state the proposition.
See also—Is used to show additional authority that supports a proposition.
See generally—Is used to identify authority that presents helpful background information
related to the stated proposition.
Accord—Is used to indicate other cases that state or support a proposition. It is placed
after the citation given in support of the proposition.
Cf—Indicates authority that supports a proposition different from but analogous to the
proposition stated.
Compare…with—Is used to compare authorities that may illustrate or reach a result
different from the stated proposition. The Bluebook and the ALWD differ somewhat in
their use of compare.
But see—Is used to identify authority that contradicts the stated proposition.
But cf—Identifies authority that supports a proposition analogous to the contrary of the
stated proposition.
Contra—Is used to identify authority that directly contradicts the stated proposition.

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2. Presentation
Capitalize the first letter of a signal that begins a sentence. Italicize or underscore signals and
separate them from the rest of the citation with a space.

3. Order of Presentation
Following is a summary of the order of presentation of authorities:
a. Constitutions—federal constitution followed by state constitutions (alphabetically by
state), then foreign constitutions (alphabetically by country)
b. Statutes—federal statutes (chronologically by title number) followed by state statutes
(alphabetically by state), then foreign statutes (alphabetically by country)
c. Cases—federal cases (starting with the highest court to the lowest court) followed by
state cases (alphabetically by state from the highest to the lowest courts), then foreign
cases (alphabetically by country)
d. Administrative and executive materials—such as the CFR or executive orders
e. Legislative materials—such as bills and legislative history
f. Secondary authority—see Bluebook R-1.3 or ALWD-46.4(c) for the order of
presentation of secondary authority

L. Sections (§) and Paragraphs (¶)—Bluebook R-3.4; ALWD-6

Insert a space before and after the section or paragraph symbol—18 U.S.C. § 2111 (1994). Do
not use at when referring to a paragraph or section. A section may include a letter as part of the
designation. In that case, the letter does not refer to a subsection. When citing consecutive
sections or paragraphs, include the first and last sections and separate the sections with a hyphen,
a long dash, or to. When citing multiple sections or paragraphs that are not consecutive, place a
comma between the sections or paragraphs and do not place and or & before the final section or
paragraph. When citing multiple subsections or subparagraphs of a single section or paragraph,
use one section or paragraph symbol.

M. Electronic Sources—Bluebook R-18; ALWD-38 to ALWD-42

Both the Bluebook and the ALWD state that if the authority is readily available in print, the
citation should be to the print source. The Bluebook and the ALWD differ in some electronic
citation details; therefore, check the rules when citing those sources.

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