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Bluebook Guide: Signals & Parentheticals

This guide introduces the Bluebook's uniform system of legal citation. This guide is best used in conjunction with the Bluebook.

Quick Notes

Both the Whitepages (R1.2, pp. 62-64) and Bluepages (B1.2, p. 4-5) provide tables containing the signals and a description of the use of the given signal.  For example, Accord is used to show that “The authority is one of multiple authorities directly stating or supporting the proposition, and one of the other authorities was mentioned in the proposition.”  See B1.2, p. 4. 

Signals

The signals in the Bluepages are not as comprehensive as those in the Whitepages.  The Whitepages also breaks down the signals by category:  (1) signals that indicate support, (2) the signal suggesting a useful comparison, (3) signals that indicate contradiction, and the signal indicating background material.  As noted previously, a Whitepage Rule may be used to supplement a corresponding Bluepages Rule.

Both the Whitepages (R1.3, p. 64) and Bluepages (B1.2, p. 5) address the placement order of the signals.  In both cases, when more than one signal is used, the signals and the pertinent authorities should be ordered in accordance with the lists provided by the Whitepages or Bluepages.  See R1.2, pp. 62-64 & B1.2, p. 4-5.  Importantly, the Bluepages direct readers to R1.3 & R1.4 for further guidance on the grouping and ordering of signals and the order of authorities, respectively. 

No signal

Use this when the cite directly supports the text, when the source is a quote, or when directly referring to something in the text.  This is used when the citation is clearly supporting the text.

E.g.

Means “for example,” and is used to indicate that the cited sources are only a small representative of a larger sample.

Accord

This is used when only one source is mentioned in the text, but additional sources are being cited.

See

This indicates that the cited source does not directly state the proposition but supports it.

See also

This can be used after a no signal cite to a “see” a cite for additional authorities.

Cf.

Refers to “compare,” and is used when an authority does not precisely support a proposition, but still supports the argument.

Compare
[   ] with [   ]

This contrasts two authorities that have different views on what you are discussing.

Contra

This is used when the authority directly contradicts the proposition.

But see

This is used when the authority implicitly contradicts the proposition.

But cf.

This is used when the authority contrasts the proposition indirectly by analogy.

See generally

This is used when the cited authority uses background material to support the text.

Parentheticals

Regardless of the type of authority cited, it may be helpful to include additional information to explain its relevance.  This information will be appended parenthetically at the end of the citation but before any subsequent history.  See  R1.5, pp. 65-66 & B1.3, pp. 5-6. 

The following examples from The Bluebook use signals and parentheticals.

Whitepages (See R1.3, p. 64)

See Mass. Bd. of Ret. v. Murgia, 427 U.S. 307 (1976) (per curiam); cf. Palmer v. Ticcione, 433 F. Supp. 653 (E.D.N.Y. 1977) (upholding a mandatory retirement age for kindergarten teachers). But see, e.g., Gault v. Garrison, 569 F.2d 993 (7th Cir. 1977) (holding that a classification of public school teachers based on age violated equal protection absent a showing of justifiable and rational state purpose). See generally Comment, O'Neil v. Baine: Application of Middle-Level Scrutiny to Old-Age Classifications, 127 U. Pa. L. Rev. 798 (1979) (advocating a new constitutional approach to old-age classifications).

Bluepages (See B1.3, p. 5)

See Flanagan v. United States, 465 U.S. 259, 264 (1984) (explaining that the final judgment rule reduces potential for parties to "clog the courts" with time-consuming appeals).

It will be noted that different typefaces are used in the Whitepages and the Bluepages.  These distinctions will be explained in another section.

Example: Compare ... with ...

When used effectively, this signal contrasts two authorities that have different views.  The following example demonstrates an artful execution of this signal.

  • Compare Cmty. Blood Bank, 405 F.2d at 1011 with Cal. Dental Ass'n. v. FTC, 526 U.S. 756 (1999) (former suggesting substantial market effect from non-profit’s activities, latter more skeptical of large market effects from operation of charities and non-profit associations).
  • Compare Model Rules of Pro. Conduct r. 1.6(b)(1) cmt. 6, with Mass. Rules of Pro. Conduct r. 1.6(b)(1), and Alaska Rules of Pro. Conduct r. 1.6(b)(1) (illustrating the differences between the ABA’s Rule 1.6 and Alaska and Massachusetts’ Rule 1.6).