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Bluebook Guide: State Cases

This guide introduces the Bluebook's uniform system of legal citation.

Reporters

State court cases can be published in multiple places.  Each jurisdiction has its own rules and practices when it comes to publishing these cases.  In some states, state court cases may be found in an official state reporter, while other states no longer publish them.

However, state court cases can also be found in regional reporters.  These unofficial publications are commercially produced and contain decisions of appellate courts from various regions of the United States.

When looking for a specific state's court cases, The Bluebook is an excellent resource.  It provides a list of which reporters cover each state's courts and notes whether a state court's cases are also published in an official reporter.  This information can be found in T1.3, pp. 242-94.  Additionally, the Regional Reporters Map lists the names of the regional reporters and the states they cover.

Important Note

When it comes to citing state court cases in legal memoranda or law review pieces, The Bluebook generally directs citations to the unofficial regional reporter rather than the official state reporter.  This is outlined in R10.3.1(b), p. 103.  If filing documents in a state court, it is important to follow the local rules for citing cases.

Regional Reporter Citation

A citation to a case in a regional reporter contains six elements.

  • Name of the case (underlined or italicized and abbreviated according to R10.2)
  • Volume of the reporter
  • Reporter abbreviation (T1)
  • First page of the case
  • State and court (abbreviated according to T1 & 10 and R10.4)
  • Year the case was decided

Here is a Bluepage example of a citation to a case for the Alaska Supreme Court in the Pacific Reporter 3d:

Alaska Inter-Tribal Council v. State, 110 P.3d 947 (Alaska 2005).

It should be noted that the parenthetical in this citation says "Alaska."  The parenthetical includes only the state here because according to R10.4(b), p. 106-07, you do not include the name of the court if the court of decision is the highest court in the state.  According to T1.3, p. 243, "Alaska" is not abbreviated.

Official State Reporter Citation

A citation to a case in an official state reporter has the same six elements set forth above. Below is a Bluepage example of how to cite a Supreme Court of Idaho case in the Idaho Reports.

Gabaldon v. W. Ada Joint Sch. Dist. #2, 169 Idaho 577 (2021).

As noted in the Regional Reporter Citation Example, the court is omitted if it is the highest court in the state.  The Bluebook also provides that the court and jurisdiction are omitted if they are "unambiguously conveyed by the reporter title."  See R10.4(b), p. 106. 

If a citation to a case is in an official state reporter, generally, a citation to that case in the regional reporter will also be required as a parallel citation.  The following Bluepage parallel citation example is from a Michigan Court of Appeals case.

People v. Haynes, 281 Mich. App. 27, 760 N.W.2d 283 (2008).

Public Domain Format

When citing a decision available in a public domain format, also known as a medium-neutral format, follow the guidelines in T1.3.  Include the case name, the year of the decision, the state's two-character postal code, the court abbreviation from T7 (unless it's the state's highest court), the sequential number of the decision, and if the decision is unpublished, include a capital "U" after the sequential number.  When citing specific material within the decision, provide a pinpoint citation to the paragraph number of the material and, if available, a parallel citation to the appropriate regional reporter.  See 10.3.3, p. 104.

The Bluebook provides the following examples for the recommended public domain citation format.  See R10.3.3, p. 105 & T1.3, p. 255.

  • Beck v. Beck, 1999 ME 110, ¶ 6.
  • Gregory v. Class, 1998 SD 106, ¶ 3.
  • Jones v. Fisher, 1998 OK Civ. App. 120U.
  • Loup v. Dube, 2014 IL 101235, ¶ 5.
  • Dube v. Loup, 2015 IL App (1st) 101214, ¶¶ 20–22.

Refer to T1.3 as a jurisdiction may have adopted a public domain format that differs from the above examples.  As such, the requirements of the jurisdiction’s format should be observed.  See R10.3.3, p. 105.

Note:  The Bluepages do not appear to address citations for the public domain format.  Refer to BT2.2, pp. 46-59 and local rules for more information.