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Bluebook Guide: Case Citations

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

Case Citations

Basic Citation

The precise format of a case citation depends on various factors, including the jurisdiction, court, and type of case. Review the rest of this section on case citations and the relevant rules in The Bluebook before trying to format a case citation for the first time. R10, pp. 100-24.

Elements of a Citation

1.  Case Names
2.  Reporters & Other Sources
3.  Court & Jurisdiction
4.  Date or Year
5.  Parenthetical Information
6.  Prior & Subsequent History

The Bluebook's Quick Style Guide provides some online examples to illustrate how to cite commonly used sources in accordance with the Whitepages, which are intended for use in law review footnotes.

Reporters

A reporter is a publication containing the opinions of a particular court or jurisdiction, organized chronologically by date of decision. The opinions of a given court or jurisdiction are often published in multiple reporters. For instance, opinions of the U.S. Supreme Court are published in three reporters: United States Reports (U.S.), Supreme Court Reports (S. Ct.), and United States Supreme Court Reports, Lawyers' Edition (L. Ed. and L. Ed. 2d). If a case is published in a reporter, The Bluebook in T1 explains which reporter is the preferred one to cite for federal and state cases.

For a law review article footnote, the first full citation of the case name is not underlined or italicized.
In court documents, a full case name is generally italicized or underlined. 

General Rules

Whitepages

Use the case name appearing at the beginning of the opinion or decision in the cited reporter and pay attention to R10.2.1, pp. 102-07, for specific directions and examples. Always keep the first word in each party’s name in full (including a relator), subject to assorted exceptions as set forth in The Bluebook. For extremely long case names, omit unnecessary words for identification. The short identifier printed at the top of each page of the case (or "the running head") may serve as a guide.

The only significant differences between case names in textual sentences and case names in citations are the italicization (R2) and the extent to which the case name is abbreviated. The provisions of R10.2.1 apply to every case name, whether in text or citations, but case names in citations are further abbreviated according to R10.2.2.

Bluepages

The proper citation method for court documents is set forth in B10, pp. 11-18. These pages are also full of "Bluepages Tips," like underlining (or italicizing) the entire case name up to but not including the comma following the case name.

Abbreviations (R10.2.1(c), p. 103)

In textual sentences, whether in the main text or footnote text, abbreviate only widely recognized initials (AARP, NAACP, NLRB, etc.) under R6.1(b), p. 93. Importantly, the following eight words are abbreviated, unless one of these eight begins a party’s name: "&," "Ass’n," "Bros.," "Co.," "Corp.," "Inc.," "Ltd.," and "No."

Descriptive Terms (R10.2.1(e), p. 104)

Omit terms such as “administrator,” “appellee,” “executor,” “licensee,” and “trustee” that describe a party already named.

  • Burns v. McMillen
  • Not: Burns v. McMillen, Administrator
  • But: Trustees of Dartmouth College v. Woodward
Given Names or Initials (R10.2.1(g), p.105)

Generally, omit given names or initials of individuals, but not in names of business firms or where a party’s surname is abbreviated.

  • Courtney v. Sandman
  • Not: Paul Vincent Courtney v. Joseph S. Sandman
  • But: Tanya Bartucz, Inc. v. Virginia J. Wise & Co.
  • But: Linda R.S. v. Richard D.
Business Firm Designations (R10.2.1(h), p. 105)

Designations like “Inc.,” “Ltd.,” “L.L.C.,” “N.A.,” “F.S.B.,” among other similar terms, will be omitted if the name also contains a word such as “Ass’n,” “Bros.,” “Co.,” “Corp.,” “Ins.,” or “R.R.,” all of which clearly indicate that the party is a business firm.  Importantly, this rule is narrowly construed. Only omit the pertinent designation if the business's name could not be mistaken for the name of some other entity.

Unions (R10.2.1(i), p. 106)

The Bluebook directs that a union name must be cited exactly as it appears in an official reporter, subject to some exceptions. See R10.2.1(i), p. 106, for examples.

  • Cite only the smallest unit.
  • The first full craft or industry designation will be cited (rather than superfluous designations)
  • Widely recognized abbreviations of the union's name may be used (e.g., AFL, IBEW, UAW).
  • Omit all prepositional phrases of location (including national or larger areas).

Examples:

  • NLRB v. Radio & Television Broadcast Engineers Local 1212
  • Not: NLRB v. Radio & Television Broadcast Engineers Local 1212, IBEW, AFL-CIO
  • Douds v. Local 294, International Brotherhood of Teamsters
  • Not: Douds v. Local 294, International Brotherhood of Teamsters, Chauffeurs, Warehousemen & Helpers
Commissioner of Internal Revenue, (R10.2.1(j), p. 106)

The Commissioner of Internal Revenue may be cited simply as “Commissioner” or, in citations, “Comm’r.”

Procedural Phrases (R10.2.1(b), p. 103)

Abbreviate the following common procedural phrases using ex rel or In re.

  • ex rel:  “on the relation of,” “for the use of,” “on behalf of,” “as next friend of,” and similar expressions.
  • In re:  “in the matter of,” “petition of,” “application of,” and similar expressions

Omit all procedural phrases except the first.  When adversary parties are named, omit all procedural phrases except “ex rel.”

Include any introductory or descriptive phrases such as “Accounting of,” “Estate of,” and “Will of.”

  • In re Will of Abreu
  • Estate of Anderson v. Commissioner

Procedural phrases must be consistently rendered in italics.  This rule applies regardless of the italicization status of the remainder of the case name.  

  • Ex parte Smith

Omit "The" as the first word of a party's name, except when it is part of the name of the object of an in rem action or when "The King" or "The Queen" is a party.  For example:

  • The Queen v. Lydon
  • In re The Thames Bridge
"The" (R10.2.1(d), p. 104)

If “The” is in an established popular name, do not omit it.

  • The Civil Rights Cases, 109 U.S. 3 (1883).
  • The Zoot Suit Riot Cases, 100 Cal. 1 (1943).

If the case is referred to in the text of the article, then omit "The."

  • The holdings in Dred Scott and the Civil Rights Cases were flawed. 
Geographic Terms (R10.2.1(f), pp. 104-05)

Generally, “State of,” “Commonwealth of,” and “People of,” should be omitted. 

  • Illinois v. Wardlow, 528 U.S. 119 (2000)
  • Florida v. Royer, 460 U.S. 491 (1983)

However, an exception exists when citing decisions of the courts of that particular state. In such a case, only “State,” “Commonwealth,” or “People” will be retained.

  • People v. Haynes, 501 Mich. 863 (2017)
  • People v. Haynes. 281 Mich. Ct. App. 27 (2008)

“City of,” “County of,” “Village of,” and “Township of,” among other expressions, should be omitted. 

  • Mayor of Chicago v. Smith (rather than Mayor of the City of Chicago v. Smith)
  • Brown v. Mayor of Waukegan 

An exception exists if the expression begins a party name.

  • McDonald v. City of Chicago
  • City of Chicago v. Morales

All prepositional phrases indicating location that do not follow "City" or similar terms should be omitted, unless removing them would leave only one word in the party's name, or if the location is part of the complete name of a business or similar entity.

  • Davis v. Board of Examiners (rather than Davis v. Board of Examiners of the City of Evanston)
  • Young v. Bank of North Chicago
  • Smith v. Mutual of Omaha

Importantly, The Bluebook provides this specific example:

Planned Parenthood of Southeastern Pennsylvania v. Casey

The foregoing example seems to align with the direction to include designations of national or larger geographical areas. Notable exceptions exist for union names (see below) and for omitting “of America” after “United States.”

  • Jackson v. People's Republic of China
  • United States v. Bank of America

Keep geographical designations that are not introduced by a preposition.

  • Oliver v. Michigan Department of Corrections
  • Miller v. Illinois Department of Motor Vehicles

Geographical designations following a comma should be omitted.

  • Mayor of Chicago v. Smith (rather than Mayor of the City of Chicago, Ill. v. Smith)
  • Brown v. Mayor of Waukegan  (rather than Brown v. Mayor of Waukegan, Ill.) 
Common Names Different from Name in Reporter (10.2.1(k), pp. 106-07)

For cases that are commonly known by a name different from the one in the reporter, you should either replace the reporter name entirely with the common name or include the common name in parentheses next to the case name as it appears in the reporter, using the same typeface.

  • The Brig Amy Warwick (The Prize Cases), 67 U.S. (2 Black) 635 (1863).
  • The Prize Cases, 67 U.S. (2 Black) 635 (1863).
  • Not: The Prize Cases (The Brig Amy Warwick), 67 U.S. (2 Black) 635 (1863).

In instances where a case is referred to by a name in the reporter but is also commonly known by a different short name, the short name cannot completely replace the reporter name in a full citation. However, the short name may be included in italics within parentheses:

  • Youngstown Sheet & Tube Co. v. Sawyer (Steel Seizure), 343 U.S. 579 (1952).
  • Not: Steel Seizure, 343 U.S. 579 (1952).

In mandamus actions involving courts, if the case is identified by the name of the judge against whom the writ is sought, the judge's name may be included in italics within parentheses. Furthermore, for cases that have multiple dispositions, it can be helpful to indicate the decision number in italics within parentheses. See R10.2.1(k), pp. 106-07, for more examples. According to R2.1(f), when citing cases under this rule, the parentheses must not be italicized in either the main text or footnotes.

Federal Court System

For information about the federal court system, visit the U.S. Courts website. See T1.1, pp. 257-60, for abbreviations for the U.S. Federal Courts, including the U.S. Supreme Court, U.S. Court of Appeals, and U.S. District Courts.

Visit the Federal Court Website Links page, which will provide access to various federal courts, including important local rules for those courts.

Federal Reporters

United States Reports is an official publication of the United States Government, and it is the preferred reporter to cite for U.S. Supreme Court cases per The Bluebook. The Supreme Court Reporter and United States Supreme Court Reports, Lawyers' Edition are other reporters for U.S. Supreme Court cases.

The Federal Reporter (for cases after 1891), as well as the Federal Appendix (for cases from 2001 to 2021), contain cases for the Circuit Courts of Appeals.
For District Court cases after 1932, use the Federal Supplement.

There are also specific reporters for the U.S. Court of Federal Claims, the U.S. Court of International Trade, and Bankruptcy Courts, among others.

Refer to T1.1 & T2 (pp. 257-72) for a detailed background of Federal Judicial and Legislative Materials.

United States Supreme Court

United States Reports

Generally, when citing a U.S. Supreme Court case, the official reporter, the United States Reports, will be used when the case is published therein. T1.1, p. 257.
A citation to a case in the United States Reports will include the following five elements: 

  • Name of the case (underlined or italicized and abbreviated according to R10.2)
  • Volume of the United States Reports
  • Reporter abbreviation (“U.S.”)
  • First page of the case
  • Year the case was decided

Bluepages

Brown v. Bd. of Educ., 347 U.S. 483 (1954).

To include a pinpoint citation, add that page number(s) after the first page of the decision.

Brown v. Bd. of Educ., 347 U.S. 483, 495 (1954).

Whitepages

Brown v. Bd. of Educ., 347 U.S. 483 (1954).

Brown v. Bd. of Educ., 347 U.S. 483, 495 (1954).

Other United States Supreme Court Reporters

While United States Reports is the preferred reporter to cite for U.S. Supreme Court cases, there can be a significant lag between when the Court decides a case and when it is published in that reporter. In these instances, citation of the case as published in one of the unofficial Supreme Court reporters, Supreme Court Reporter or United States Supreme Court Reports, Lawyers' Edition, will be necessary. According to The Bluebook, citation to the Supreme Court Reporter is preferred over the United States Supreme Court Reports, Lawyers' Edition. T1.1, p. 257.  It should be noted that the volume and page numbers for each unofficial reporter will be different than those found in the United States Reports.

Bluepages

  • Brown v. Bd. of Educ., 74 S. Ct. 686 (1954). 
  • Brown v. Bd. of Educ., 98 L. Ed. 873 (1954).

Whitepages

  • Brown v. Bd. of Educ., 74 S. Ct. 686 (1954).
  • Brown v. Bd. of Educ., 98 L. Ed. 873 (1954).
Parallel Citations

A parallel citation is the same case reported in a different publication. Most courts (including the U.S. Supreme Court) and attorneys use parallel citations to both of the aforementioned unofficial reporters when citing to U.S. Supreme Court decisions. While this practice is not required, applicable local rules should be consulted. The order for United States Supreme Court parallel citations is U.S.; S. Ct; L. Ed.:

Mincey v Arizona, 437 U.S. 385; 98 S. Ct. 2408; 57 L. Ed. 2d 290 (1978).

As noted above, if a cite for the United States Reports is not yet available, the proper citation form dictates that the format ___ U.S. ___ should be used followed by a parallel cite to a printed source.

Local Rules

Be mindful that local rules in various jurisdictions may contain different citation guidelines.  For instance, the Style Manual for the Supreme and Appellate Courts of Illinois (p.49) provides the following direction for United States Supreme Court Decisions. Generally, the Illinois Style Manual calls for citation to the United States Reports (U.S.) as stated in The Bluebook (T1).  

However, the Illinois Style Manual indicates that for a decision that has not yet been reported in the United States Reports advance sheets, leave a blank for the beginning page number, as well as any required pinpoint, and add a citation to the Supreme Court Reporter (S. Ct.), including any applicable pinpoint page.

Full citation:  Miller v. Alabama, 567 U.S. ___, ___, 132 S. Ct. 2455, 2460 (2012).
Short citation:  Miller, 567 U.S. at ___, 132 S. Ct. at 2460.
Id. citation:  Id. at ___, 132 S. Ct. at 2460.

The Illinois Style Manual further provides that it is always preferred to include a volume number, even if it has yet to be published. Volume numbers can be found on the Opinions of the Court page.

United States Courts of Appeal

Decisions for federal courts of appeals are not compiled in an official reporter, as there is no official, government-published reporter for the federal appellate courts of appeals or the federal district courts.  

As such, many decisions from the courts of appeals are published in West's Federal Reporter. If a court of appeals case is published in the Federal ReporterThe Bluebook provides the citation standard in T1.1, p. 258.

West's Federal Appendix was a compilation and publication of “unpublished” (technically “non-precedential” and literally paradoxical) decisions from the Federal Courts of Appeals from 2001 to 2021.

A citation to a court of appeals decision in the Federal Reporter has six elements: 

  • Name of the case (underlined or italicized and abbreviated according to R10.2)
  • Volume of the Federal Reporter
  • Reporter abbreviation (F., F.2d, or F.3d)
  • First page of the case
  • Name of the court (abbreviated according to R10.4)
  • Year the case was decided

Bluepages

Shakman v. City of Chi., 426 F.3d 925, 936 (7th Cir. 2005).

Whitepages

Shakman v. City of Chi., 426 F.3d 925, 936 (7th Cir. 2005).

United States District Courts

As noted above, cases from the federal district courts are not compiled in an official reporter.  Rather, cases from the district courts are published in West's Federal Supplement. Citation rules for published district court cases are set forth in The Bluebook in T1.1, p. 259.

A citation to a district court case in the Federal Supplement includes the same six elements as set forth above for federal appellate cases, except that the reporter abbreviation will be "F. Supp." or "F. Supp. 2d." 

Bluepages

United States v. Bd. of Sch. Comm'rs, 506 F. Supp. 657, 672 (S.D Ind. 1979).

Whitepages 

United States v. Bd. of Sch. Comm'rs, 506 F. Supp. 657, 672 (S.D Ind. 1979).

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.

More information on specific states can be found in T1.3, pp. 272-325. Additionally, the Regional Reporters Map lists the names of the regional reporters and the states they cover.

Which Sources to Cite

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. 108. 

If filing documents in a state court, it is important to follow the local rules for citing cases. The Bluebook notes, "Many state rules require that citations to state court decisions include a citation to the official state reporter, followed by a parallel citation to a regional reporter." R10.3.1(a), p. 108.

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. 111, 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. 273, "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). 

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).

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. 111.

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. 109-10 & T1.3.

  • Beck v. Beck, 1999 ME 110, ¶ 6.
  • Gregory v. Class, 1998 SD 106, ¶ 3.
  • Jones v. Fisher, 1998 OK Civ. App. 120U.

The following are examples of Illinois cases.

  • Loup v. Dube, 2014 IL 101235, ¶ 5.
  • Dube v. Loup, 2015 IL App (1st) 101214, ¶¶ 20–22.
  • Choy v. Hart, 2025 IL App (2d) 240745-U

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. 110.

Note:  The Bluepages do not appear to address citations for the public domain format. Refer to BT2.2, pp. 50-63, and local rules for more information.

Style Sources

The Bluebook provides specific information on sources from Illinois.  See T1.3, pp. 255-56.

The Illinois Supreme Court adopted a new Style Manual for the Supreme and Appellate Courts of Illinois to apply to opinions filed on or after January 1, 2025. The style manual presents several small refinements to existing practices. The longtime practice is to generally follow the standards of The Bluebook (the Style Manual follows the 21st edition at this point).

The Style Manual provides guidance in the following areas: (1) Structuring an Opinion (pp. 1-24), (2) Grammatical Style (pp. 25-46), and (3) Citation Style (47-92).  

The Style Manual notes that a good practice is to stay consistent with The Bluebook rules as much as possible.

Significantly, the Style Manual indicates that typeface conventions for legal writing from The Bluebook (the Bluepages) should be used in Illinois reviewing court opinions.

The Style Manual designates a preference for 12-point, Times New Roman font (and 11-point, Times New Roman font for footnotes).

Illinois Deviations for The Bluebook

Noteworthy exceptions and partial exceptions to The Bluebook are stated in italics above the relevant rules within the Style Manual. Not all rules below represent a departure from The Bluebook rules; many expand upon the rules for authorities specific to Illinois practice. Note that a good rule of thumb is to avoid deviating from The Bluebook rules as much as possible.

Some Signals are not Italicized

The Style Manual contains a key exception to R1.2, where most signals are not italicized. 

Below is a list of signals, in their correct typeface and with their appropriate commas.

Accord 
But cf. 
But see 
Cf. 
Compare 
Contra
E.g.,
See
See also
See, e.g.,

The “see also” signal is not used until after “see” or another supporting signal is used.

Remember

 

When citing decisions from Illinois Reports or Illinois Appellate Court Reports, it is important to include the appropriate references. For decisions made in 2011 and beyond, the state's public domain opinions citation system should be used.

While parallel citations to the North Eastern Reporter are not required, they are permitted under Illinois court rules. See p. 85. Make sure to stay informed and accurate when citing legal decisions in Illinois.

Illinois Cases

Illinois Published Opinions

In the past, Illinois decisions were published in official state reporters: Illinois Reports for Illinois Supreme Court decisions and Illinois Appellate Court Reports for the appellate decisions.  Illinois Supreme Court and Appellate Court decisions are also available in the commercial reporters: the North Eastern Reporter and West's Illinois Decisions.

In 2011, the state stopped the production of printed official reporters and started to issue electronic versions of Illinois Supreme Court and Appellate Court decisions on the Illinois courts website. Illinois decisions are still available in the North Eastern Reporter and West's Illinois Decisions.

Always cite Illinois’s official reports (Illinois Reports (Ill. or Ill. 2d) or Illinois Appellate Court Reports (Ill. App., Ill. App. 2d, or Ill. App. 3d)) for opinions published therein.

For Illinois cases filed on or after July 1, 2011, and for any case not published in the Illinois Official Reports prior to that date and for which a public-domain citation has been assigned, the public-domain citation shall be given, and where appropriate, pinpoint citations with paragraph numbers shall be given.

The Style Manual provides helpful examples of how to cite public-domain opinions.

Full citation People v. White, 2011 IL 109689
Full citation with pinpoint People v. White, 2011 IL 109689, ¶ 139
Full citation with a pinpoint to a footnote People v. White, 2011 IL 109689, ¶ 12 n.2
Short citation White, 2011 IL 109689
Short citation with pinpoint White, 2011 IL 109689, ¶¶ 63-64

Parallel Citations

Parallel citations of the North Eastern Reporter (N.E. or N.E.2d), Illinois Decisions, Westlaw, and Lexis-Nexis are not used. Each of those unofficial reporters and sources contains Illinois’s official citation for cases, and so citation of parallel reporters prolongs the opinion without increasing access for the reader. 

However, the Style Manual provides that parallel citation to regional reporters is acceptable for other jurisdictions. See pp. 48-49.

Examples

Style Manual Examples

This is for cases in which parallel citation information is included.

Full citation People v. Sharpe, 216 Ill. 2d 481, 487, 839 N.E.2d 492, 498 (2005)
Short citation People v. Sharpe, 216 Ill. 2d 481, 487, 839 N.E.2d 492, 498 (2005)
Id. citation Id. at 487

Law Review Purposes

Parallel citation information may only be included for the public domain opinions' first full citation. Note that no pinpoint citation is given to a regional reporter for public-domain cases' parallel citations. The following examples are representative of the public domain format of Illinois cases in law review articles.

Full citation Snyder v. Heidelberger, 2011 IL 111052, ¶ 1, 953 N.E.2d 415
Short citation Snyder, 2011 IL 111052, ¶ 1
Id. citation Id. ¶ 2

Random Examples

  • Linden Bros. v. Practical Elec. & Eng'g Publ'g Co., 309 Ill. 132, 140 N.E. 874 (1923).
  • People v. Hansen, 2011 IL App (2d) 081226, 952 N.E. 82.
  • People v. Hansen, 952 N.E.2d 82 (Ill. App. Ct. 2011).
  • Lewis v. Rutland Twp., 359 Ill. App. 3d 1076, 824 N.E.2d 1213 (2005).
  • Jastram v. Lake Villa Sch. Dist. 41, 192 Ill. App. 3d 599, 549 N.E.2d 9 (1989).

Small Distinction

In practice, the terms "unpublished case" and "unreported case" are used interchangeably; however, there is a nuanced distinction between these terms.  

Unpublished Case

  • The court has placed a citation limitation on the opinion – there is typically some language in the document that provides explicit instructions on when the case can and cannot be cited or a reference to a court rule that delineates that information.
     
  • The court has rendered the opinion not citable.
     
  • The court will not release the opinion to the public.

Unreported Case

The case has not been published in a hard copy reporter series, such as the West Regional and Federal Reporters from the National Reporter System (F.3d, N.E.2d, etc.).

 

Applicability of Unpublished Opinions

In the legal domain, courts designate opinions as "unpublished" if they do not add anything new to the respective body of law. Consequently, an opinion is considered published unless explicitly labeled as unpublished. It is worth noting that only a small percentage of cases are designated for publication by a court and subsequently published in a reporter. However, many cases are unpublished but still available in legal databases such as Westlaw, Lexis, and Bloomberg Law.

It is imperative to exercise caution when using unpublished opinions. Courts have varying rules and regulations regarding the acceptability of citations to unpublished opinions. Nevertheless, Federal Rule of Appellate Procedure 32.1 provides that a court of appeals may not prohibit a party from citing an unpublished opinion of a federal court for its persuasive value or any other reason. This rule applies only to unpublished opinions issued on or after January 1, 2007. The citation of unpublished opinions issued before that date would continue to be governed by the local rules of the circuits.

In Illinois, Supreme Court Rule 23 initially allowed reviewing courts in Illinois to issue decisions as unpublished orders if the ruling does not establish law and is, therefore, not precedential. However, the amendment to Rule 23, effective from January 1, 2021, now allows these unpublished orders to be cited for persuasive purposes.

Citation of Unpublished or Unreported Opinions

The Bluebook describes how to cite unpublished or unreported cases, and there are examples in the chart at the beginning of R10, pp. 100-01, and as part of R10.8.1, pp. 117-19. According to R10.8.1, there are two types of sources for unpublished cases: (1) cases available on widely available electronic databases and (2) cases available in slip opinions. 

Cases Available on Electronic Media

When a case is unreported but available on a widely used electronic database, it may be cited in that database.  Provide the case name, docket number, database identifier, court name, and full date of the most recent major disposition of the case. Cite the case docket number exactly as it appears.  If the database contains codes or numbers that uniquely identify the case (as do Westlaw (WL), Lexis (LEXIS), and Bloomberg Law (BL)), these must be given. Screen or page numbers, if the database assigns them, should be preceded by an asterisk; paragraph numbers, if assigned, should be preceded by a paragraph symbol.  

Examples for Whitepages (See generally R10.8.1(a), pp. 117-18)

WestLaw

  • Int'l Snowmobile Mfrs. Ass'n v. Norton, No. 00-CV-229-B, 2004 WL 2337372, at *3, *7 (D. Wyo. Oct. 14, 2004).
  • Shelton v. City of Manhattan Beach, No. B171606, 2004 WL 2163741, at *1 (Cal. Ct. App. Sept. 28, 2004).

Lexis

  • Gibbs v. Frank, No. 02-3924, 2004 U.S. App. LEXIS 21357, at *18–19 (3d Cir. Oct. 14, 2004).
  • Chavez v. Metro. Dist. Comm'n, No. 3:02CV458(MRK), 2004 U.S. Dist. LEXIS 11266, at *5 n.3 (D. Conn. June 1, 2004).
  • See Illinois v. City of Chicago, No. 17-cv-6260, 2018 U.S. Dist. LEXIS 139061, *9-10 (N.D. Ill. Aug. 16, 2018).
  • United States v. City of Albuquerque, No. CV 14-1025 RB/SMV, 2015 U.S. Dist. LEXIS 198541, *11 (D.N.M. Feb. 19, 2015).

Bloomberg

  • Ortho-McNeil Pharm., Inc. v. Teva Pharm. Indus., Ltd., No. 2008-1549, 2009 BL 181480, at *4 (Fed. Cir. Aug. 26, 2009).

Examples for Bluepages (See generally B10.1.4, p. 15)

WestLaw

  • Hoban v. Funk, No. 22-1630, 2024 WL 546718 (7th Cir. Feb. 12, 2024).
  • Del Signore v. Nokia of Am. Corp., No. 20 C 4019, 2023 WL 3292570, at *4 (N.D. Ill. May 5, 2023).

Lexis

  • Hatch v. City of Milwaukee, No. 21-2805, 2022 U.S. App. LEXIS 8014 (7th Cir. Mar. 28, 2022).
  • Mathews v. City of S. Bend, No. 3:10cv390, 2013, U.S. Dist. LEXIS 69893, at *3 (N.D. Ind. May 16, 2013).

Bloomberg

  • Hatch v. City of Milwaukee, No. 21-2805, 2022 BL 104541 (7th Cir. Mar. 28, 2022).
  • City of Beaumont v. Mathews, No. 09-10-00198-CV, 2011 BL 268220, at *1-2 (Tex. App. Aug. 31, 2011).

Slip Opinions

When a new case has been issued but has not been added to a reporter yet, it is available as a slip opinion. The Bluebook has helpful guidelines for citing such cases (B10.1.4, p. 15-16 & R10.8.1(b), p. 118-19). If a case is unreported but can be found as a slip opinion, simply include the docket number, court, and full date of the most recent disposition of the case.  Keeping track of all this information will make it easier to access and cite the case in the future.

Examples for the Whitepages (See generally R10.8.1(b), pp. 118-19)

  • Groucho Marx Prods. v. Playboy Enters., No. 77 Civ. 1782 (S.D.N.Y. Dec. 30, 1977).
  • Ross v. Weissman, No. 90-345, slip op. at 6 (D. Mass. Dec. 4, 1990).

Examples for the Bluepages (See generally B10.1.4, pp. 15-16)

  • Kitchens v. Grohman, No. 90-345, slip op. at 6 (D. Mass. Dec. 4, 1990).
  • Free Range Content, Inc. v. Google Inc., No. 14-cv-02329-BLF, slip op. at 4 (N.D. Cal. Aug. 25, 2015).

Introduction

In the 21st edition, The Bluebook included citations for cases involving enslaved persons. The single paragraph and two examples were a small start to this large issue, with cases involving enslaved persons often conflating traditional legal categories by treating individuals as property. This confusion can lead to these cases being misused by contemporary legal professionals. The 22nd edition did not add any additional content. 

Citing Slavery Project

Recent scholarship has examined the ongoing reliance of courts on cases involving slavery, highlighting a failure to recognize their obsolescence and the frequent presence of racially prejudiced reasoning within these decisions. 

Professor Simard initiated the Citing Slavery Project to uncover the impact of slavery law in American law and to make that research accessible to others.  The project offers a database of more than 3,000 historical slave cases and their continued citation in modern cases as precedent.  The project reflects that American entities, from corporations to educational institutions, are acknowledging and dealing with the lasting impact of slavery.  Importantly, the project contends that it is essential for the legal profession to thoroughly examine its historical ties to this abhorrent period of American history and take necessary steps to make reparations.

Key Articles

Justin Simard, Citing Slavery, 72 Stan. L. Rev. 79 (2020).  Available via Hein.

David J. S. Ziff, Citation, Slavery, and the Law as Choice:  Thoughts on Bluebook Rule 10.7.1(d), 101 N.C. L. Rev. F. 72 (2022-2023).  Available via Hein.

The Bluebook's Slave Cases

The twenty-first edition of The Bluebook provides a rule (R10.7.1(d), p. 116) in the Whitepages, without guidance or explanation, for citing cases involving enslaved persons.

For cases involving an enslaved person as a party, use the parenthetical "(enslaved party)." For cases involving an enslaved person as the subject of a property or other legal dispute but not named as a party to the suit, use the parenthetical “(enslaved person at issue).” For other cases involving enslaved persons, use an adequately-descriptive parenthetical (emphasis included in rule 10.7.1(d)).

As examples, The Bluebook provides the following two illustrative citations from the Whitepages (including the proper citation to Dred Scott v. Sandford):

  • Dred Scott v. Sandford, 60 U.S. (19 How.) 393 (1857) (enslaved party), superseded by constitutional amendment, U.S. Const. Amend. XIV.
  • Wall v. Wall, 30 Miss. 91 (1855) (enslaved person at issue).

Background for the Rule 10.7.1(d)

This rule follows a 2020 article in the Stanford Law Review by Professor Justin Simard, which discusses how courts continue to rely on cases involving enslaved persons without acknowledging their outdated status or the racist reasoning often used in these decisions. In Citing Slavery, Professor Simard details "the living law of slavery" (pp. 94-107) and provides cases where judges address the harms of citing slave cases (pp. 113-115).

In the referenced key articles, the authors start with the principle of utilizing precedent in legal arguments, which is rooted in the notion that a current case possesses substantial similarity to a previous case.  Accordingly, such a case should be resolved in a similar manner. This principle retains its authoritative force irrespective of the personal agreement or disagreement of legal practitioners with the outcome of the prior case. Therefore, contemporary objections to the institution of slavery, no matter their strength, may not necessarily detract from the relevance of a case involving slavery as a legal precedent.

Professor Simard found that courts fail to address the underlying racism in many of these decisions and do not discuss the cases' slavery context in 80 percent of citations. The law still significantly relies on cases involving enslaved persons in various fields, including contracts, property, evidence, civil and criminal procedure, statutory interpretation, and torts. The recent scholarship highlights the ongoing use of "slave cases" by courts and legal professionals, where decisions involving enslaved individuals either as parties or as the subject property are cited in modern legal opinions, even though their rulings might have been invalidated by the Thirteenth or Fourteenth Amendments.

Thoroughly steeped legal traditions evolve slowly.  Professor Simard suggests that the legal professional tends to favor the side of continuity, and issues a stern rebuke for the continued citation of cases involving enslaved persons (pp. 124-25). 

Practical Applications of Rule 10.7.1(d)

Legal professionals, including judges, have a significant practical interest in the new Bluebook rule for citing cases involving enslaved persons.  Implicitly, this rule encourages the reassessment of the ongoing use of such cases as precedential authority.  While many courts call for practitioners to follow The Bluebook for citations, most jurisdictions are unclear on the Bluepages-Whitepages divide.  

This distinction between Bluepages rules and Whitepages rules may seem insignificant, but it matters for properly citing cases involving enslaved persons. Importantly, The Bluebook rules require an academic writing or a law review article to note the slavery context of an authority. Notably, the rule for citing slavery is buried in a subsection of the section on "prior and subsequent history." A Whitepage rule may be used to supplement a corresponding Bluepage rule. However, because the Bluepages specifically provide a guide for the citation needs of legal professionals, the afore-referenced subsection in the Whitepages may be easily overlooked. Ultimately, a judge or an attorney relying on a case involving slavery in real litigation, affecting real parties, and involving a judgment of the state that carries the force of law would not be obligated to provide such information.

In Citation, Slavery, and the Law as Choice, Professor Ziff asserts that Rule 10.7.1 (d) is misplaced in the Whitepages. The editors of The Bluebook apparently rejected this focus and placed the rule in a section not applicable to judges, attorneys, or other practitioners—the very targets of Professor Simard's article. Professor Ziff advocates that courts adopt Rule 10.7.1(d) independently as part of the relevant courts' local rules. The editors' failure to expand upon the rule in the 22nd edition underscores Professor Ziff's criticism. 

Fifth Circuit History

The United States Court of Appeals for the Fifth Circuit originally covered Florida, Georgia, Alabama, Mississippi, Louisiana, and Texas.  In 1948, the Fifth Circuit gained appellate jurisdiction over the United States District Court for the Canal Zone.  On October 1, 1981, the Fifth Circuit was split, with Alabama, Georgia, and Florida being moved to the new Eleventh Circuit.  On March 31, 1982, the Fifth Circuit lost jurisdiction over the Panama Canal Zone, which was transferred to Panamanian control.

Current Configuration

The Fifth Circuit consists of Louisiana, Mississippi, and Texas.

Determining Precedential Decisions

Following the split, the Fifth Circuit was divided into two administrative units: Unit A (corresponding to the new Fifth Circuit) and Unit B (corresponding to the new Eleventh Circuit). This division raised new and complex issues regarding precedent.

In the new Fifth Circuit, decisions of the former Fifth Circuit are binding, regardless of the date and unit. This approach was logical because the "new" Fifth Circuit was a continuation of the old Fifth Circuit.

The rules regarding binding precedent in the new Eleventh Circuit are more complicated. Former Fifth Circuit cases decided on or before September 30, 1981, are binding precedent in the Eleventh Circuit unless they have been overruled by the Eleventh Circuit judges sitting en banc.

As for decisions of the former Fifth Circuit handed down after September 30, 1981, Unit B decisions and en banc decisions are binding precedent in the Eleventh Circuit, unless they have been overruled by the Eleventh Circuit judges sitting en banc.

Unit A en banc decisions and Unit A panel decisions decided after September 30, 1981, are only considered persuasive precedent in the Eleventh Circuit.

Citation Rules

Naturally, The Bluebook sought to instill citation order to the Fifth Circuit Split. Under R10.8.2, p. 119, The Bluebook provided directions to cite cases decided during the transitional period leading to this reorganization according to the following rules.

  • Cite decisions rendered in 1981 and labeled “5th Cir.” by month.
     
  • Give unit information whenever available.
     
  • Designate as “Former 5th Cir.”

In the section cited above, The Bluebook provides the following examples:

  • Birl v. Estelle, 660 F.2d 592 (5th Cir. Nov. 1981).
     
  • Haitian Refugee Ctr. v. Smith, 676 F.2d 1023 (5th Cir. Unit B 1982).
     
  • Trailways, Inc. v. ICC, 676 F.2d 1019 (5th Cir. Unit A Aug. 1981) (per curiam).
     
  • McCormick v. United States, 680 F.2d 345 (Former 5th Cir. 1982).

Examples from Tepley's Legal Citation in a Nutshell

The following examples are from Teply's excellent Legal Citation in a Nutshell. This first example would be binding precedent in the new Fifth Circuit, but it would only be a persuasive precedent in the new Eleventh Circuit.

McGowen v. Faulkner Concrete Pipe Co., 659 F.2d 554 (5th Cir. Unit A Oct. 1981)

The following case would be binding precedent in the new Fifth Circuit, as well as in the Eleventh Circuit.

LaBanca v. Ostermunchner, 664 F.2d 65 (5th Cir. Unit B Dec. 1981)

Teply highlights that some cases decided after September 30, 1981 (but submitted for decision before that date) are labeled in the Federal Reporter as a “Former Fifth Circuit case” without providing unit information. These cases, often en banc, have an asterisk indicating that the statute splitting the court specified that further proceedings “shall be had in the same manner and with the same effect” as if the split had not occurred. These cases must be identified as “Former 5th Cir” as set forth in the following example.

Kite v. Marshall, 661 F.2d 1027 (Former 5th Cir. 1981)

See Larry L. Teply, Legal Citation in a Nutshell 133-35 (3d ed., 2021).

General Principles

It is important to adhere to a specific format when citing briefs, court filings, transcripts, and other court documents. Each document should start with its full name, abbreviated according to R10.2.1(c), followed by a pinpoint citation, if applicable. Next, the full case citation and the docket number should be included after the document's name and the pinpoint citation.

If there has been no decision on the filing cited, the case should be cited according to rule 10.5(c), with the date in the parenthetical reflecting the date on which the filing was made, regardless of subsequent dispositions such as oral arguments.

If a decision has been rendered, the case should be cited per standard citation practices. See R10.8.3, p. 119-21.

Bluebook Examples

The Bluebook provides a number of examples as part of R10.8.3, pp. 114-16. The examples include the following items.

  • Complaint & Amended Complaint
  • Appellate Brief
  • Transcripts
  • Amicus Briefs
  • Audio Recordings of Oral Arguments
  • Short Forms

This research guide will be updated on a regular basis with more examples of briefs, court filings, transcripts, and more.

Bluepages

In the Bluepages, Court and Litigation Documents are covered as part of B17, pp. 25-27. This material is addressed in Section Bluepages 17 in this Research Guide.

Examples

Assorted Examples for UIC Law's Institutional Repository

UIC Law's clinical faculty and students have filed several documents in federal and state courts.  Some documents have been used here for illustrative citation purposes.  

  • Petitioner’s Response to the Court’s Order to Show Cause at 10, Johnson v. Pfister, No. 1:17-cv-03997 (N.D. Ill. 2017).
  • Amended Complaint at 5-9, Weiner v. Prairie Park, Docket No. 1:16-cv-01889 (N.D. Ill. 2016).
  • Brief for bin Ali Jaber as Amicus Curiae Supporting Appellants at 5-10, bin Ali Jaber  v. United States, Docket No. 16-05093 (D.C. Cir. 2016)
  • Petition for Writ of Certiorari at 29-30, Mackey v. Milam, 527 U.S. 1035 (1999) (No. 98-1564).
  • Brief for Respondents at 1-7, City of Cuyahoga Falls v. Buckeye Cmty. Hope Found., 538 U.S. 188 (2003) (No. 01-1269).

Visit UIC Law's Court Documents and Proposed Legislation.

Other Examples

All court filings must adhere to a standardized format. Initially, include the complete title of the document as it appears in the filing, abbreviated by R10.2.1(c). Subsequently, provide a pinpoint citation, if applicable. Thereafter, the full case citation and docket number should be included.  (Example 1 below).

When a decision has not yet been rendered on the cited filing, it is important to cite the case according to R10.5(c). However, ensure that the date within the parenthetical reflects the date on which the filing was made, regardless of any developments that may have occurred subsequently, such as oral arguments. In cases where a decision has been issued, the citation should be formatted in the standard manner.

It is essential to always incorporate the docket number, either parenthetically when a reported citation is utilized or as part of the citation when no reported citation is present. (Example 2 below).

While not mandatory, including the document number assigned by the court (as in a PACER filing for federal cases) may also be appropriate if it is critical for the document’s location. (Example 4 below).

  1. Complaint at 17, Kelly v. Wyman, 294 F. Supp. 893 (S.D.N.Y. 1968) (No. 68 Civ. 394).
  2. Complaint, United States ex rel. Anti-Discrimination Ctr. of Metro N.Y., Inc. v. Westchester Cnty., 668 F. Supp. 2d 548 (S.D.N.Y. 2009) (No. 06 Civ. 2860 (DLC)).
  3. Brief of Petitioner-Appellant at 48, United States v. Al-Marri, No. 03-3674 (7th Cir. Nov. 12, 2003).
  4. Amended Complaint & Demand for Jury Trial, Viola v. Am. Brands, Inc., No. 85-2496-G (D. Mass. Aug. 1, 1985), Dkt. No. 14.
  5. Brief for R Street Institute et al. as Amici Curiae Supporting Petitioners at 5-6, Mylan Pharms. Inc. v. UCB, Inc., 586 U.S. 1146 (2019) (No. 18-692).

Consent Decrees

Sometimes, a touch of creativity is necessary to craft a suitable citation that comports with The Bluebook. In one recent UIC Law Review article, six Consent Decrees are referenced. Rule 10.8.3 was followed to produce a citation for the Consent Decrees. In looking at this rule, hereinafter was utilized to differentiate between the various consent decrees.

  • Full citation: Consent Decree, Illinois v. City of Chicago, No. 17-cv-620 (N.D. Ill. Jan. 31, 2019) [hereinafter Consent Decree (Chicago)].
  • Short citation: Consent Decree (Chicago), supra note 102, at 17.

Ordinarily, the court document could be used with a supra form, but there were six Consent Decrees in this case. The docket number must also be provided if the court document and case name are used for the short citation. This might create confusion because cases related to the Consent Decrees are also used in the footnotes.

According to The Bluebook, a case name cannot be part of a "hereinafter" or "supra" formulation. The Bluebook provides a vague direction on this point on p. 121: " the court document itself may be cited using a supra form, unlike the case, which may not."  See also R4.2, p. 85, for the preclusion of using supra and hereinafter with a case name. Ultimately, this was a court document with an identifier in the parenthetical, so hereinafter was used according to R10.8.3, p. 121.

Explanation

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.

Parallel Citations in the Whitepages

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. 257-60 & T1.3, pp. 272-325.

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. 108.

Parallel Citations in the Bluepages

In the Bluepages, documents submitted to state courts, all case citations should be to the reporters required by local rules. See B10.1.3, p. 15. 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. 33. To find local rules for the court to which you submit a document, refer to BT2.2, pp. 50-63.

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.

Pledger v. Halvorson, 324 Ark. 302, 921 S.W.2d 576 (1996).

Kenford Co. v. Cnty. of Erie, 73 N.Y.2d 312, 537 N.E.2d 176, 540 N.Y.S.2d 1 (1989).

Short Form 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. 121-24. 

For court documents, consult the Bluepages, B10.2, pp. 17-18, to use a short form citation for cases already cited in full in briefs, filings, legal memoranda, and other court documents.

Elements

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

1. Name of the case

2. Volume of the reporter

3. Reporter abbreviation

4. Pinpoint citation to specific page referenced preceded by “at”

Whitepages

General Rule

The Bluebook provides strict guidelines for the use of short form citations in footnotes. See R10.9(a), p. 121-22. 

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.  

Example

The Bluebook, p. 121-22, provides 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.

Other Notes

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. 124.

Bluepages

General Principles

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. See B10.2, pp. 17-18.

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.

Tidbits

Space Savers

The Whitepages (R4, pp. 83-87) 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 Rule

  • 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 & Hazardsupra 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.

Basic & Random

The Bluebook, pp. 100-01, provides this table as an example of basic citation forms for various documents for academic legal writing. 

Examples for the Bluepages are provided throughout B10, pp. 11-17.  

Additionally, there are some examples in its Quick Style Guide.

 

Example of Basic Case Citation from The Bluebook Rule 10.1

Minutiae

Small Details: The Bluebook gets into granular detail on most of its topics; this is particularly so with its treatment of case names.

Key Sections

  • General Rules for Case Names (R10.2.1, pp. 102-07)
    Covering party names, abbreviations, procedural phrases, words to omit, geographical terms, business designations, IRS Commissioner, among other things.
     
  • Reporters & Other Sources (R10.3, pp. 108-10)
    Among other information, it discusses parallel citations and public domain formats.
     
  • Court & Jurisdiction (R10.4, pp. 110-11)
    Every case citation must identify the court that decided the case, including the court's name and geographical jurisdiction in parentheses following the citation, along with the decision date or year.
     
  • Date or Year (R10.5, p. 112)
    Provide the year of decision if available; use the term year only if not. 
     
  • Parenthetical Information Regarding Cases (R10.6, pp. 113-14)
    There will often be additional information about a case provided in parentheticals. The following examples are as law review footnotes.

Parker v. Randolph, 442 U.S. 62, 84 (1979) (Stevens, J., dissenting).

Zadvydas v. Davis, 533 U.S. 678, 719 (2001) (Kennedy, J., dissenting) (citing Shaughnessy v. United States ex rel. Mezei, 345 U.S. 206 (1953)).

  • Prior & Subsequent History (R10.7, pp. 114-17)
    A representative example: Cent. Ill. Pub. Serv. Co. v. Westervelt, 342 N.E.2d 463 (Ill. App. Ct. 1976), aff’d, 367 N.E.2d 661 (Ill. 1977).
     
  • Special Citation Forms (R10.8, pp. 117-21)
    This material includes pending and unreported cases; briefs, court filings, and transcripts; and more.