A parallel citation simply means the same case will be reported in a different publication. When citing law review articles, it is important to use the relevant regional reporter, but if an official public domain citation is available, it should also be provided alongside the parallel citation. When it comes to court documents, be sure to follow the local rules for required case citations. Keeping these guidelines in mind can help ensure accuracy and clarity in your legal writing.
Also, review more information related to parallel citations in the section on short citation formats.
Many state court decisions are published in two or more sources. The comprehensive federal and state jurisdictions table provides guidance for which reporters to cite for the decisions of most courts. See T1.1, pp. 227-30 & T1.3, pp. 242-94.
The Bluebook initially provides guidance with respect to documents submitted to state courts, where all case citations must be to the source(s) required by local rules. According to many state rules, citations to state court decisions must include a citation to the official state reporter, followed by a parallel citation to a regional reporter. Importantly, these local rules, and not the citation rules related to state courts in T1.3 govern state court filings. As discussed below, the Bluepages provide further guidance concerning jurisdiction-specific citation rules for court documents.
Next, The Bluebook advises that in all other documents the relevant regional reporter, if the decision is found therein, must be used for citation purposes. If the decision is available as an official public domain citation, such as in Illinois, that citation must be provided along with a parallel citation to the regional reporter (if available). See R10.3.1(b), p. 103.
The Bluepages direct that for documents submitted to state courts, all case citations should be to the reporters required by local rules. See B10.1.3, p. 14. The Bluepages provide a list of local court rules governing legal citations. The Bluebook notes that "the list is intended to be as accurate and comprehensive as possible, [but] it is important for practitioners to check the most recent version of local rules on official court websites." See BT2, p. 30. To find local rules for the court to which you submit a document, refer to BT2.2, pp. 46-59.
In some cases, local rules require the citation of both the official state reporter and the unofficial regional or state-specific reporter, which is called a parallel citation. Where a pinpoint cite is necessary, include one for each reporter citation. When the state or court is clear from the official reporter title, omit it from the date parenthetical. The Bluebook provides helpful examples to illustrate this latter point.