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Bluebook Guide: Short Form Citation

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

Purpose

A lot of time was spent learning how to cite cases in long form or stated differently and how to cite a case for the first time in a court document or law review article.

Because a case or other legal materials will often be cited multiple times in a document, The Bluebook established a “short form” for use in subsequent citations.  

The Whitepages explain when to use a short form citation for cases or other legal materials already cited in full in law review articles.  See R10.9, pp. 116-18. 

For court documents, consult the Bluepages, B10.2, pp. 16-18, to use a short form citation for cases already cited in full in briefs, filings, legal memoranda, and other court documents.

Generally, a short form for a case has the following elements:

  • Name of the case
  • Volume of the reporter
  • Reporter abbreviation
  • Pinpoint citation to specific page referenced preceded by “at”

Whitepages Short Form Citation

The Bluebook provides strict guidelines for the use of short form citations in footnotes.  See R10.9(a), p. 116. 

A short form for a case may be used if it clearly identifies a case that 

  • is already cited in the same footnote or 
  • is cited (in either full or short form, including id.) in one of the preceding five footnotes. 
  • In any other cases, a full citation would be required.  

The Bluebook, at 116 gives the following example using a string of footnotes.

1 United States v. Montoya de Hernandez, 473 U.S. 531 (1985).

2 Id. at 537–38.

3 See United States v. Martinez-Fuerte, 428 U.S. 543, 557 (1976); In re Draughon Training Inst., Inc., 119 B.R. 921, 926 (Bankr. W.D. La. 1990).

4 See Martinez-Fuerte, 428 U.S. at 550; In re Draughon Training, 119 B.R. at 930.

5 New York v. Belton, 453 U.S. 454, 457 (1981).

6 See id. at 456.

7 See Montoya de Hernandez, 473 U.S. at 540.

8 See Martinez-Fuerte, 428 U.S. at 550.

If a case has been cited in full in the same general discussion, then it may be referred to by one of the parties’ names without further citation.  See R10.9(c), p. 118.

Another points to consider is that when using only one party's name in a short form citation, avoid using the name of a geographical or government unit, a government official, or another common litigant, as in footnotes 4, 7, and 8.  See R10.9(a)(i), p. 117.

Bluepages Short Form Citation

Once a full citation to an authority has been provided, a “short form” in later citations of the same authority may be used, so long as (1) it is clear to the reader which authority is referenced; (2) the full citation falls in the same general discussion; and (3) the reader will have little trouble locating the full citation.  

There are several acceptable short form citations for a case.  These forms include “at” followed, if necessary, by a pinpoint cite.

Here are examples of acceptable short forms for Trafficante v. Metro. Life Ins. Co., 409 U.S. 205 (1972), provided that the page referenced in the text was on page 210.

Trafficante, 409 U.S. at 210. • 409 U.S. at 210. • Id. at 210.

As in the Whitepages, the Bluepages use the name of the first party in a short form citation, unless that party is a geographical unit, a governmental entity, or another type of common litigant. 

Additionally, a long party name may be shortened, for example from First Nat’l Trust & Inv. Corp. to First Nat’l, as long as the reference remains unambiguous.

The short form citations take a slightly different form for cases with parallel citations.  The case Chalfin v. Specter, 426 Pa. 464, 465, 233 A.2d 562, 563 (1967), is presented as an example of how to do short form citation for a case with a parallel citation.

Chalfin, 426 Pa. at 465, 233 A.2d at 563. • 426 Pa. at 465, 233 A.2d at 563.