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Bluebook Guide: Id., Supra & “Hereinafter”

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

Space Savers

The Whitepages (R4, pp. 79-82) and the Bluepages (B4, p. 8) both address the short citation forms of id., supra, and "hereinafter."  These are space savers of court documents or law review articles.

Unwritten Rule

In law reviews, there is often an unwritten rule not to use "ids." more than five times in a row.  Consult the faculty advisors and student editors on a journal's practice in this regard.

General Rules

  • Id. is used to denote a previously cited source.
  • Though "ids." can be very helpful, pay close attention to the rules about when you can use them, dependent on the material type and what the preceding footnote that the "id." is referring to contains.
  • Note the period is part of the "id." and as such, should also be italicized.
  • Supra refers to a portion in an earlier part of the document.
  • “Hereinafter” means “in the following part” of a document.  
  • It is important to know when (and when not) to use supra and “hereinafter.”
  • Supra and “hereinafter” may be used to refer to legislative hearings; court filings; books; pamphlets; reports; unpublished materials; nonprint resources; periodicals; services; treaties and international agreements; regulations, directives, and decisions of intergovernmental organizations; and internal cross-references.
  • Importantly, for supra in the law review footnote context, indicate the footnote in which the full citation can be found.  
  • Supra and “hereinafter” should not be used to refer to cases, statutes, constitutions, legislative materials (other than hearings), restatements, model codes, or regulations.  
  • There is an exception for regulations, where supra or “hereinafter” may be used when the name of the authority is extremely long.
  • Do not use the “hereinafter” form when a simple supra form is adequate
  • The Bluebook provides a lot of information, but the best way to show how to use id., supra, and “hereinafter” is through examples.

Examples for Law Review Footnotes

1 Chalfin v. Specter, 233 A.2d 562, 562 (Pa. 1967).

2 Id. at 563.

3 42 U.S.C. § 1983.

4 See id. § 1981.

5 Fleming James, Jr. & Geoffrey C. Hazard, Jr., Civil Procedure §§ 1.3–.5 (3d ed. 1985).

6 See id. § 1.7.

7 See Chalfin, 233 A.2d at 570.

James & Hazard, supra note 5, § 7.21; W. Page Keeton et al., Prosser and Keeton on the Law of Torts § 1, at 2 (5th ed. 1984).

Richard H. Fallon, Jr. et al., Hart and Wechsler’s The Federal Courts and the Federal System 330 (5th ed. 2003).

10 Keeton et al., supra note 8, § 2, at 4.

11 Proposed Amendments to the Federal Rules of Criminal Procedure: Hearings Before the Subcomm. on Crim. Just. of the H. Comm. on the Judiciary, 95th Cong. 92–93 (1977) [hereinafter Hearings] (statement of Prof. Wayne LaFave).

12 Fallon et al., supra note 9, at 343.

13 Hearings, supra note 11, at 100.