Chapter 7: Introduction to Citation

Citation is the method that tells the reader of legal documents the source of the legal or factual statement that the citation follows. The reader, when given information to find the source on their own, can assess whether the source is (1) a primary or secondary authority; (2) a mandatory or persuasive authority; (3) credible to the reader; and (4) relevant to the issue being discussed.

You should use a consistent citation format with which the reader is familiar because it makes it easier for the reader to check the sources you cite. This, in turn, enhances your credibility as a writer because you are making it easier for the reader to follow what you are saying.

The Bluebook: A Uniform System of Citation, Columbia Law Review Ass'n et al. eds., (21st ed. 2020), is considered the standard for legal citation, and we will use this citation manual for this class. There are other citation manuals, and some states have even developed their own. Be sure to use the proper citation format for your particular jurisdiction.

Parts of the Bluebook

The Bluebook has five parts.

1. Quick References (inside front and back covers)
2. Practitioner’s Notes (blue pages)
3. Rules (white pages)
4. Tables and Abbreviations
5. Index

For this class, plan to use the Practitioner’s Notes, which we will refer to as the blue pages, as these are the rules for functional legal documents like memoranda and briefs. The Rules, or white pages, are for scholarly legal writing like law review articles. There will be times when you will have to look in the white pages for the full rule.

Citation Forms

Rules indicated are the start for creating your citations; this is not an exhaustive list.

Citation clause/Textual sentence

Rules: B.1, R1.1.

When you insert the citation as a clause into part of a sentence.

Ex: For instance, in Sweatt v. Painter, 339 U.S. 629 (1950)...

Citation sentence

Rules: B.1, R1.1.

When the citation comes after the sentence for which you need to provide support.

Ex: The Equal Protection Clause extends to admitting students to law schools. Sweatt v. Painter, 339 U.S. 629 (1950).

Full citation

Rules: B10.1.1-3; R10-10.5.

The complete citation to the source, including every component required by the appropriate Bluebook rule. Use the full citation the first time you cite any source.

Parallel citation

Rules: B10.1.3, R10.3.1.

A citation that provides information on where to find the source in multiple resources. You will most often encounter this for case citations because cases are often published in multiple reporters; for instance, Georgia cases can be found in both the state reporter and also in the regional reporter. Whether to use parallel citations depends on your jurisdiction and court’s preference. 

Pinpoint citation

Rules: B10.1.2, R3.2.

A citation, either full or short, that indicates the specific page on which the reader can locate the proposition you state the source supports. Use a pinpoint citation, or pincite, whenever you (1) quote, (2) paraphrase, or (3) refer to a specific part of the source you are citing. When in doubt, pincite. A pinpoint citation allows the reader to quickly find the specific part of the source you are using to support your statement.

1. Directly quote the source

“[T]he issue in the present case is whether C.P.R. violated the Student Handbook, a quintessentially factual question that we must review under the “any evidence” standard, construing the record in the light most favorable to the Henry County Board's decision.” C.P.R. v. Henry Cty. Bd. of Educ., 329 Ga. App. 57, 65 (2014).

1. Paraphrase the source

The proper standard of review in a case with factual questions is one that construes the record most favorably to the prevailing party’s position in the court below. C.P.R. v. Henry Cty. Bd. of Educ., 329 Ga. App. 57, 65 (2014).

1. Reference to specific part in the source

After a lengthy discussion as to the Appellant’s various arguments to the contrary, the court finally stated the correct standard to apply. C.P.R. v. Henry Cty. Bd. of Educ., 329 Ga. App. 57, 62-65 (2014).

Short citation

Rules: B4, B10.2, R4, R10.9.

The abbreviated citation. Use the short citation only after you have cited the source fully. A short citation will either contain some of the identifying information from the full citation or will be a use of id.; all short form citations can be used to provide pinpoint citations.

Signals

Rules: B1.2, R1.2–1.4.

Signals are words that are placed before the source citation to indicate the relationship between the legal proposition and the source. Signals add meaning to your writing because they tell the reader why the citation is included.

There are four categories of introductory signals: (1) signals that indicate support; (2) signals that indicate comparison; (3) signals that indicate contradiction; and (4) signals that indicate background material. As you move forward in your legal writing career your use of signals will expand. This class only focuses on signals used to indicate support, as this is the most common type used by practitioners.

The signal should be italicized or underlined, depending on which you are using for the piece of legal writing on which you are working. The space between the signal and the rest of the citation should not be underlined or italicized. Only capitalize a signal if it begins a sentence, not if it merely comes after a semicolon.

Signals Used to Indicate Support

[no signal]

When you do not use a signal, you are indicating to the reader that the cited authority (1) directly states the proposition, (2) identifies the source of a quotation, or (3) identifies an authority referred to in the text.

Ex: A complaint does not “require heightened fact pleading of specifics, but only enough facts to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007).

e.g.,

When you use e.g., the cited authority states the proposition. Other authorities state the proposition, but citing to them is unnecessary. It may be used alone or attached to another signal. When attached to another signal, it should be preceded by an underlined (or italicized) comma and followed by a non-underlined (or non-italicized) comma.

Ex: A student should begin outlining in late September. E.g., Mangan v. Wells, 123 U.S. 456, 458 (2022).

Accord

Accord is tricky and rarely used. Ignore it for this class.

See

See is used when the cited authority indirectly supports the proposition; there is an inferential step between the authority cited and the proposition it supports.

Ex: A complaint need not include every relevant fact, but at least some facts must be alleged. See Ashcroft v. Iqbal, 556 U.S. 662, 680 (2009) (holding that conclusory allegations in a complaint will not survive a 12(b)(6) motion).

See also

See also is used when the cited authority is additional source material that supports the proposition. See also is often used when speaking in general terms, offering more examples of a proposition, or when discussing authority that is less binding. If you use see also, be sure to include a parenthetical.

Ex: Surviving a Rule 12(b)(6) motion to dismiss requires that a party’s complaint contain more than conclusory allegations; at least some facts must be alleged that give rise to an inference of plausibility. Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007); see also Adam Steinman, The Pleading Problem, 62 Stan. L. Rev. 1294 (2010) (tracking the pleading complexities that have arisen after the Supreme Court’s decisions in Twombly and Iqbal).

Cf.

Cf. is used when the cited authority supports a proposition different from the main proposition but sufficiently analogous to lend support. Parentheticals are highly encouraged here.

Ex: An assault is a tort that occurs when a person causes another to reasonably fear imminent harm; a battery is a tort that occurs when a person suffers physical harm due to a touching. Cf. Vosburg v. Putney, 50 N.W. 403 (holding that intent to touch qualifies as battery).

You can use multiple signals within one citation sentence or clause. Use of multiple signals complement each other, offer important guidance to the reader, and enhance your writing. In particular, see and see also are often used together. When you begin using signals that serve purposes other than support, you will notice that see and but see are commonly used together.

Direct v. Inferential Support

Direct Support. The cited portion of the authority matches the proposition. Note that this can be via a quotation or paraphrase.

Inferential Support. The cited portion of the authority does not exactly match the proposition, but it is flows from it.

Short Forms and Signals

Short forms may be used with signals following the ordinarily rules for short forms as discussed in Rules B4, B10.2, R4, and R10.9. That being said, when the immediately preceding citation is a string citation, id. cannot be used.

Parentheticals

Rules: B1.3, R1.2–R1.5, R10.1, R10.6, R12.8

Explanatory parentheticals are used to explain the relevance of cited authority. They are used in myriad forms of legal writing: judicial opinions, memoranda, briefs, restatements, and more. Just like the use of multiple signals can enhance your writing, properly used parentheticals enhance credibility, improve your arguments, and make your writing more concise. Be judicious yet instructive with parentheticals.

Parentheticals should either be a full quote, or phrases that begin with a present participle (a verb ending in -ing).

Ex:

1. Modern day battery law stems from the late 19th century. See Vosburg v. Putney, 50 N.W. 403 (1889) (establishing that intent to harm is not required for a person to be liable for battery).
2. See Ashcroft v. Iqbal, 556 U.S. 662, 680 (2009) (holding that conclusory allegations in a complaint will not survive a 12(b)(6) motion).
3. Bell Atl. Corp. v. Twombly, 550 U.S. 544, 547 (2007) (“[T]he Court is not requiring heightened fact pleading of specifics, but only enough facts to state a claim to relief that is plausible on its face.”).See Ashcroft v. Iqbal, 556 U.S. 662, 680 (2009) (holding that conclusory allegations in a complaint will not survive a 12(b)(6) motion).
   1. See Ashcroft v. Iqbal, 556 U.S. 662, 680 (2009) (holding that conclusory allegations in a complaint will not survive a 12(b)(6) motion).

Parentheticals should be used with the following signals: see, see also, see generally, Cf., Compare . . . with, and But cf. Sentences often contain more than one parenthetical. Consult Rule 1.5, which lays out the order in which parentheticals should appear in the citation.

String citation

Rule: R1.4.

A citation that consists of citations to multiple authorities that are connected to each other in a certain way. You will most often encounter this when citing multiple cases that support the same proposition stated or when citing multiple cases to explain from where you synthesized a legal rule.

Citation Examples

Common Citation Questions

Should I use italics or underlining?

The Bluebook allows you to use either italics or underlining for case names. For this class, you will use underlining because, quite simply, it is easier for me to see whether you have formatted your citation correctly. Many firms and judges prefer italics. As with so much in legal writing, be sure to consult your local rules, standing orders, or style guides when deciding whether to use italics or underlining for documents you produce outside of this class. Also, be sure to stay consistent with your choice of italics or underlining.

Which citation do I use?

The first time you cite a source, you must provide the full citation and you cannot break any of the pieces apart. Sometimes this results in awkward-looking sentences. For instance, when considering Sweatt v. Painter, 339 U.S. 629 (1950), …The next time you discuss the same case, however, you can rely on a short citation, either the shortened version of the full citation or id., depending on which one is appropriate. 

How do I reference multiple pages in a citation?

If the information you are citing is on more than one page and there are no interruptions to that information, you will use a dash between the page numbers. Use just the last two numbers of the second page number.

• Smith v. Beck, 123 Ga. App. 456, 457-59 (2019).
• Ali v. Ali, 657 Ga. 1234, 1235-47 (2010).
• Sleeping Beauty v. Maleficent, 77 Disney 1004, 1005-07 (1950).

If the information you are citing is on more than one page and there are interruptions to that information, you will use a comma between the page numbers. Use the complete page number for each page on which the information is found.

Smith v. Beck, 123 Ga. App. 456, 457, 459 (2019).

• Ali v. Ali, 657 Ga. 1234, 1235, 1240, 1247 (2010).
• Sleeping Beauty v. Maleficent, 77 Disney 1004, 1005, 1007 (1950).

How do I cite two cases that discuss the same thing? 

The following are correct: 

• In Smith and Jones, the court recognized XYZ. 123 Ga. App. at 457; 111 Ga. App. at 223.
• In Smith v. Beck, 123 Ga. App. 456, 457 (2019), and Jones v. Rutledge, 111 Ga. App. 222, 223 (2020), the court recognized XYZ. 

Some writers believe that in-line citations should be avoided at all costs, and others believe that using split citations should be avoided at all costs. You will have to decide which format is better for you.

How do I cite a sentence that requires two citations to two different parts of the sentence? 

First, consider whether your sentence is likely too long and you should split the sentence into two smaller sentences. If division into smaller sentences does not work, the following are correct:

• [First part of sentence], [long cite to case 1], [second part of sentence], [long cite to case 2]. 
• [First part of sentence], [long cite], [second part of sentence], [short cite].
• [First part of sentence], [short cite], [second part of sentence], [long cite].
• [First part of sentence], [short cite], [second part of sentence], [short cite].

For example, "Courts have concluded that a battery has occurred when [fill in facts], [short/long cite to case 1], and also when [fill in facts] [short/long cite to case 2]." So, even though you normally place short citations as a separate citation sentence, you make an exception when you cite a sentence that requires two citations to two different parts of the sentence. 

Further, if you need to cite a very large page range (e.g., the facts you use are on page 1 and the holding is on page 65), it would be helpful to your reader if you employed this technique. The rationale is that attribution trumps readability. Remember that if the information is not your original thought, you must let the reader know from whence the information came. 

"Can I use 'id.' in a string cite?" 

If the first case in your string cite refers to the immediately preceding case, yes! But you may not use "id." after a string cite. So the following is correct: 

• [Sentence] Brown, 456 Ga. App. at 320. [Sentence]. Id. at 321; Smith, 123 Ga. App. at 22; Jones v. Rutledge, 111 Ga. App. 222, 223 (2020). 

However, the following is not correct.

• [Sentence]. Brown, 456 Ga. App. at 320; Smith, 123 Ga. App. at 22; Jones v. Rutledge, 111 Ga. App. 222, 223 (2020). [Sentence]. Id. at 321.

Conclusion

This chapter is intended to serve as an overview to what a citation is and why it is necessary. For more in-depth treatment of the mechanics of putting together a citation, refer to The Bluebook and other resources.