There are two ways to make a citation, in a citation sentence or in a citation clause.
In a legal academic piece, like a law review article, all citations appear in footnotes appended to the portions of the text to which they refer. See R1.1, p. 61.
For a non-academic legal document, such as a brief or an opinion, a citation will generally appear in the text of the document and follow the proposition to which the citation supports. In this writing environment, footnotes are only used when permitted or required by local court rules. See B1.1, p. 3.
Citation Sentences and Clauses in Law Reviews
In the Whitepages, citations to authority supporting or contradicting a proposition made in the main text of a law review article (or other law school assignment) will be placed in a footnote. For more mechanics on footnotes relating to placement thereof and other uses for footnotes, see R1.1(a), p. 61. When a footnote contains a statement that requires support, a citation to the relevant authority should appear directly after the statement as a citation sentence or a citation clause. The Bluebook provides specific explanations and examples of citation sentences and clauses. See R1.1(b)(i), R1.1(b)(ii) & R1.1(c).
Citation Sentences and Clauses in Court Documents
The difference for the Bluepages is that the citation is placed directly in the body of the text following the statement for which the citation supports. The byproduct will often result in a lengthy sentence in a court document, as the following example from The Bluebook illustrates. See B1.1, p. 4.
The Supreme Court adopted a broad reading of the Commerce Clause during the New Deal, see Wickard v. Filburn, 317 U.S. 111, 128–29 (1942), though in recent years the Supreme Court has reined in its broad reading somewhat, see United States v. Lopez, 514 U.S. 549, 624 (1995); United States v. Morrison, 529 U.S. 598, 612–13 (2000); Nat'l Fed'n of Indep. Bus. v. Sebelius, 132 S. Ct. 2566, 2587 (2012); but see Gonzales v. Raich, 545 U.S. 1, 39 (2005).
The following examples demonstrate how a sample sentence and clause would appear in a court document (Bluepages) and in a law review footnote (Whitepages).
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Citation Sentence |
Citation Clause |
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Bluepages |
In any suit in federal court, the issue of standing presents a threshold jurisdictional question. Greater New Orleans Fair Hous. Action Ctr. v. Kelly, 364 F. Supp. 3d 635, 646 (E.D. La. 2019). |
Defendants rely on La. ACORN Fair Hous. v. LeBlanc, 211 F.3d 298 (5th Cir. 2000), to argue that plaintiff does not have standing. |
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Whitepages |
In any suit in federal court, the issue of standing presents a threshold jurisdictional question. Greater New Orleans Fair Hous. Action Ctr. v. Kelly, 364 F. Supp. 3d 635, 646 (E.D. La. 2019). |
Defendants rely on La. ACORN Fair Hous. v. LeBlanc, 211 F.3d 298 (5th Cir. 2000), to argue that plaintiff does not have standing. |
When a case name is grammatically part of the sentence, it should be italicized, as shown in the second Whitepages example. R2.2(b)(i), pp. 70-71.
The Bluebook provides the following examples of how a sentence will look in a court document and law review article. See R2, p. 68.
Court Document
Directors manage the business and affairs of a corporation. See Revlon, Inc. v. MacAndrews & Forbes Holdings, Inc., 506 A.2d 173, 179 (Del. 1986); see also Del. Code Ann. tit. 8, § 141(a) (2000). In Guth v. Loft, the court held that directors also owe a duty of loyalty to the shareholders. 5 A.2d 503, 510 (Del. 1939) (holding that directors’ duty of loyalty demands that “there shall be no conflict between duty and self-interest”).
Law Review Article
Directors manage the business and affairs of a corporation.1 In Guth v. Loft, the court held that directors also owe a duty of loyalty to the shareholders.2
1 See Revlon, Inc. v. MacAndrews & Forbes Holdings, Inc., 506 A.2d 173, 179 (Del. 1986); see also Del. Code Ann. tit. 8, § 141(a) (2000).
2 5 A.2d 503, 510 (Del. 1939) (holding that directors’ duty of loyalty demands that “there shall be no conflict between duty and self-interest”).