Lessons on the Bluebook rules

Citation sentences and citation clauses

A citation can be a citation sentence or a citation clause. Which one you use determines where the citation goes and how it is punctuated.

What the rule does

Every time you state a proposition from a source, you cite the source. The Bluebook gives you two ways to attach the citation to your text:

Citation sentence

A citation sentence stands on its own, immediately after the sentence whose proposition it supports. It begins with a capital letter, ends with a period, and can hold multiple citations separated by semicolons.

Citation clause

A citation clause supports only part of a sentence. It is set off by commas (or sometimes parentheses), is not capitalized as if starting a sentence, and does not get its own end-of-sentence period.

Why the rule exists

Readers need to know exactly which proposition a citation supports. A citation sentence supports the whole previous sentence. A citation clause supports only the proposition next to it.

Common mistakes

• Treating a citation clause like a sentence. Don't put a period after a citation clause that is mid-sentence — use commas.
• Stacking unrelated citations into one sentence. If two citations support different propositions, use two citation clauses (or rewrite the sentence).
• Forgetting the closing period. A citation sentence ends with a period, just like any other sentence.

Introductory signals

A signal is a word or phrase before a citation that tells the reader how the source supports your point.

The signals you need first

No signal

No signal at all means the source directly states the proposition, or you have just quoted from it.

See

Use see when the source supports the proposition implicitly or in a one-step-removed way. The source clearly leads to your point, but doesn't state it.

E.g.

Use e.g. when the source directly states the proposition, but it's only one of several sources that do. You're giving an example, not the complete list. E.g. is always followed by a comma.

Combining see and e.g.

You can combine the two as see, e.g., when both things are true: the sources support your point implicitly (the see part), and they're just examples from a larger body of authority (the e.g. part).

Why combine them? Each half tells the reader something different. See warns them there's a small inferential step between the source and your sentence. E.g. tells them you aren't citing every case, so they shouldn't assume the authorities you list are the only ones out there. Using both keeps you accurate on both counts without padding your citation with a long string of cases.

Watch the punctuation: a comma after see and another after e.g., then the citation.

Why the rule exists

Signals tell the reader which sources state your point directly, which support it by inference, and whether you are citing every source or only examples.

Explanatory parentheticals

An explanatory parenthetical is a short note in parentheses that tells the reader what a source says or does, and why you cited it. The Bluebook allows three forms.

Wherever you use one, it goes at the very end of the citation, after the court-and-year parenthetical.

1. A present-participle phrase

The most common form. Start with an -ing verb — holding, finding, explaining, rejecting — in lowercase, and don't put a period inside the parentheses.

2. A quoted complete sentence

You can quote a full sentence from the source. Because it's a complete sentence, it begins with a capital letter and ends with its own punctuation inside the quotation marks.

3. A short phrase

When a few words say enough in context, a short phrase works on its own, with no verb. This is especially handy in a string cite, where each parenthetical points out the one fact that matters about each case.

What doesn't work

A complete sentence that isn't a quotation is not one of the three forms. Neither is a past-tense verb. Rewrite either one as an -ing phrase.

Why the rule exists

A parenthetical tells the reader what a source contributes, provides more detail, or gives the reader context.

The full case citation

A full case citation has five parts. The B10 lessons that follow cover each part.

Anatomy

The five parts in order

1. Case name — see B10.1.1.
2. Reporter citation — volume number, reporter abbreviation, first page of the case. See B10.1.2.
3. Pinpoint page(s) — the specific page(s) you are relying on. Always include one when you state a specific proposition.
4. Parenthetical with court and year — see B10.1.3.
5. (Optional) Weight-of-authority or explanatory parenthetical, then subsequent history.

Lessons B10.1.1 through B10.1.3 take each part one at a time.

String citations

A string citation cites more than one authority for the same proposition. Put the full citations one after another in a single citation sentence, separated by semicolons, with one period at the very end.

• Each authority keeps its own complete citation — case name, reporter, pinpoint, and court-and-year parenthetical.
• A signal at the front of the string covers every authority after it until a new signal appears.
• Don't confuse a string citation with a parallel citation, which gives two locations for the same case.

Case names

Start with the parties' names as they appear at the top of the opinion. Shorten and abbreviate them using the rules below, and italicize the case name.

Core rules

• Italicize the entire case name, including the v. The comma after the case name is not italicized.
• Use only the first party on each side. If a side lists three plaintiffs, you cite the first one only.
• Drop "et al.", "and others", and most procedural phrases (e.g., "individually and on behalf of all others similarly situated"). Keep "ex rel." and "in re" when they are part of the official name.
• Use "v." not "vs." Always lowercase, no italics on the period.
• For individuals, use only the last name. "John Q. Smith" becomes "Smith". For businesses, use the full name as listed, then apply Table 6 abbreviations.

Abbreviations in case names

Case names use the abbreviations in Table 6 (covered later in this guide). Common ones: "Corporation" becomes Corp., "Company" becomes Co., "United States" stays "United States" when it is a party, "Brothers" becomes Bros., "Department" becomes Dep't.

Geographic terms

State, city, and country names within a party's name are abbreviated per Table 10: a company named "North Carolina Light & Power" becomes N.C. Light & Power. The twist: when the place is the party, don't abbreviate it. Write out "United States" or "North Carolina" when it is itself a party.

"State," "Commonwealth," and "People"

When a state is a party, the caption often reads "State of North Carolina" or "Commonwealth of Virginia." How you write it depends on which court decided the case (Rule 10.2.1(f)):

• Citing a decision from that state's own courts — use just State, Commonwealth, or People. A North Carolina court's decision in "State of North Carolina v. Lawrence" is State v. Lawrence, 365 N.C. 506 (2012).
• Citing a decision from any other court — drop "State of," "Commonwealth of," or "People of" and use the state's name. The U.S. Supreme Court's decision is North Carolina v. Alford, 400 U.S. 25 (1970).

The reason: in a state's own courts, there's no doubt which state "State" means. Anywhere else, the reader needs the name.

"In re" and "Ex parte"

Some cases have no opposing party (bankruptcies, juvenile cases, attorney discipline). Cite them with the procedural phrase italicized along with the name: In re Marriage of Smith, Ex parte Jones.

Why the rule exists

Case names appear in tables of authorities, indexes, and briefs. Formatting them the same way every time makes cases easy to find and keeps citations short.

Common mistakes

• Italicizing the comma after the case name. Don't.
• Spelling out "v." (it's an abbreviation, not the Latin versus).
• Keeping "et al." in the case name.
• Forgetting to abbreviate Table 6 words like Corp. and Co.

Reporters and pinpoint pages

The middle of a case citation tells the reader where to find the case: volume, reporter, first page, and pinpoint, in that order. There is no period after the volume number.

The reporter sandwich

Format: volume · reporter abbreviation · first page, then a comma, then any pinpoint pages.

Which reporter to cite

For most cases, cite the official reporter if one exists. Otherwise, use the regional or West reporter. Federal cases:

• U.S. Supreme Court — cite U.S. (official). If not yet in U.S., use S. Ct., then L. Ed. as a last resort.
• Federal courts of appeals — F., F.2d, F.3d, or F.4th, depending on year.
• Federal district courts — F. Supp., F. Supp. 2d, F. Supp. 3d.

Pinpoint pages

The pinpoint page is the page where the specific material you are citing appears. You almost always need one. A citation with only the first page tells the reader "this case is somewhere on these pages"; a pinpoint tells them "look here".

• Add the pinpoint after the first page, separated by a comma: 347 U.S. 483, 495.
• For a range of pages, use a hyphen and give only the last two digits of the second page: 483-89. Do not write out the full second number, as in 483-489. The exception is a range that crosses into a new hundred, where you write the second page in full: 498-502.
• For multiple non-consecutive pinpoints, list them comma-separated: 483, 489, 495.
• If you are citing the first page itself, repeat it: 347 U.S. 483, 483.

Spacing inside reporter abbreviations

Bluebook spacing: close up adjacent single capital letters (with or without periods), but insert a space between a single letter and a longer abbreviation.

• U.S. — two single capitals, closed up
• F.3d — closed up (the "3d" is treated as part of the unit)
• F. Supp. — space, because "Supp." is longer than one letter
• S. Ct. — space, same reason

Why the rule exists

The order of volume, reporter, and page matches how reporters are organized: find the reporter, then the volume, then the page.

Court and year of decision

The last parenthetical of a full citation tells the reader which court decided the case and when. The court is omitted when the reporter already identifies it.

The rule, in one sentence

Put the deciding court's abbreviation and the year of decision in parentheses at the end of the citation. Omit the court when the reporter itself tells the reader which court decided the case. That's true whenever a reporter publishes decisions from only one court.

The examples below aren't separate rules to memorize. Each one is the same question applied to a different reporter: can the reader tell the court from the reporter alone?

Examples of when you'd omit the court

• U.S. Supreme Court — U.S., S. Ct., and L. Ed. publish only Supreme Court decisions. Just give the year: (1982).
• North Carolina Supreme Court — N.C. publishes only that court's decisions. Just the year: (2010).
• North Carolina Court of Appeals — N.C. App. publishes only that court's decisions. Just the year: (2015).

Examples of when you'd include the court

• Federal courts of appeals — F., F.2d, and F.3d publish decisions from every circuit, so show which one: (4th Cir. 2018).
• Federal district courts — F. Supp. publishes decisions from districts all over the country, so show the district: (E.D.N.C. 2020), (S.D.N.Y. 2014).
• Regional reporters — S.E., S.E.2d, and S.E.3d cover several states and several courts in each. If you cite only the regional reporter, include the state and court: (N.C. 2012) for a North Carolina Supreme Court case, or (N.C. Ct. App. 2015) for a Court of Appeals case.

Examples

Why the rule exists

Knowing the court tells the reader the weight of the authority. A Fourth Circuit decision and a Western District of North Carolina decision are not the same. Omitting the court when the reporter already names it keeps the citation short without losing that information.

Short-form citation

After you've cited a case in full once, you can use a short form. There are two kinds: the case-name short form and id.

The case-name short form

After a full citation, you may use a shortened form on subsequent references. The standard short form is: one party's name (italicized), then the volume and reporter abbreviation, "at", then the pinpoint page.

• Use the first party's name. The exception: if the first party is a government — the United States, a state, or a state's name — use the other party's name instead. So United States v. Garcia becomes Garcia, State v. Beatrice becomes Beatrice, and North Carolina v. Alford becomes Alford.
• Drop the year, the court, and the first page. Keep the volume, reporter, and pinpoint.
• Italicize the case name (one party) — and only the case name.

Id.

Id. means "the same source as the one I just cited". Use it only when the immediately preceding citation refers to a single source.

• Same page: Id. — that's it.
• Different page: Id. at 822.
• The period after id. is part of the abbreviation; the entire word and period are italicized.
• Don't use id. after a string cite (more than one source), or when something in between would confuse the reader.

Short forms for statutes

Once you've cited a statute in full, later citations can be shorter. Start with the full citation, year and all:

After that, pick the short form based on what you cited immediately before:

• Same section, and it's the immediately preceding citation: Id.
• A different section or subsection of the same code, and the code is the immediately preceding citation: any of these three forms.
  • Id. § 14-72(b).
  • § 14-72(b).
  • N.C. Gen. Stat. § 14-72(b).
• Something else was cited in between (so you can't use id.): either of these two forms.
  • § 14-72(b).
  • N.C. Gen. Stat. § 14-72(b).

In the third line, § 14-72(b). or N.C. Gen. Stat. § 14-72(b). would also be correct. In the last line, N.C. Gen. Stat. § 14-72(b). would also be correct, but id. would not, because the case came in between.

• Short forms drop the year. The year belongs in the full citation.
• You can repeat "N.C. Gen. Stat." in a short form, as long as you leave out the year.
• Keep the space between Id. and the section symbol: Id. § 14-72(b).

Why the rule exists

Repeating a full citation every time takes up space. A short form points the reader back to the full citation, and id. tells the reader you are citing the same source as the citation just before it.

Common mistakes

• Forgetting the word "at" in the short form. Harlow, 457 U.S. 820 is wrong — it should be Harlow, 457 U.S. at 820.
• Using id. after a string cite.
• Italicizing only "Id" and not the period — italicize both.
• Adding the year to a statute's short form. § 14-72(b) (2023) should be just § 14-72(b), and N.C. Gen. Stat. § 14-72(b) (2023) should be N.C. Gen. Stat. § 14-72(b).

Constitutions

Constitutional citations are short: the abbreviated name of the constitution, then the provision, from largest unit to smallest.

Federal constitution

State constitutions

Same pattern, with the state's abbreviation from Table 1 in front:

The details

• Use roman numerals for articles and amendments (art. I, amend. XIV) and arabic numerals for sections and clauses (§ 8, cl. 3).
• Don't add a date for a provision that's currently in force.
• There's no short form other than id. For any later reference that can't use id., repeat the full citation.

Regulations

Agencies issue regulations, which are collected in administrative codes. Cite them much like statutes: title, code, section, and year.

Federal regulations

Final federal regulations are collected in the Code of Federal Regulations (C.F.R.). Give the title number, C.F.R., the section, and the year of the edition you used.

North Carolina regulations

North Carolina's regulations are collected in the North Carolina Administrative Code. Same pieces, same order:

The details

• The year is the year of the code edition you used, just like a statute.
• Check Table 1 for each jurisdiction's administrative code abbreviation. Formats vary from state to state.

Citing North Carolina authorities

North Carolina has its own reporters and its own statutory compilation. Table 1 tells you what abbreviations and parentheticals to use for each.

The three sources you'll see most

North Carolina Supreme Court

Cite to N.C. — the official North Carolina Reports. Because N.C. publishes decisions from only the North Carolina Supreme Court, the reporter already tells the reader which court decided the case. You do not include the court in the parenthetical. Just the year.

If a parallel citation to the regional reporter is required (sometimes by local rule), add it after the official cite. Depending on when the case was decided, that regional reporter may be S.E., S.E.2d, or S.E.3d. For example: State v. Lawrence, 365 N.C. 506, 723 S.E.2d 326 (2012). The Parallel citations lesson covers how to write these in full and in short form.

North Carolina Court of Appeals

The intermediate appellate court. Cite to N.C. App. (official reporter, the North Carolina Court of Appeals Reports). N.C. App. publishes decisions from only the North Carolina Court of Appeals, so — just like N.C. — the reporter tells the reader which court decided the case. Leave the court out of the parenthetical. Just the year.

Pay attention to the spelling: N.C. App. is the reporter; N.C. Ct. App. is the court abbreviation. You'll still need N.C. Ct. App. in the parenthetical when you cite a Court of Appeals case only to a regional reporter, because S.E.2d alone doesn't tell the reader which court decided it.

North Carolina General Statutes

Cite the official compilation N.C. Gen. Stat.. The standard form is the section symbol, the section number, and a parenthetical with the year of the volume or supplement you used.

• Use the section symbol § for one section, §§ for a range or list.
• Cite by chapter and section: § 14-72 means Chapter 14, Section 72.

Why these rules exist

Every jurisdiction has its own reporter system. Table 1 standardizes the abbreviations so a brief filed in California can cite a North Carolina case without confusion. The rule "omit the court when the reporter makes it obvious" works the same way for both North Carolina reporters: N.C. and N.C. App. each publish decisions from only one court, so neither needs the court in the parenthetical.

Common mistakes

• Adding "(N.C. 2012)" to an N.C. cite, or "(N.C. Ct. App. 2015)" to an N.C. App. cite — the reporter already identifies the court. Just the year.
• Confusing N.C. App. (the reporter) with N.C. Ct. App. (the court in the parenthetical).
• Writing N.C.G.S. instead of N.C. Gen. Stat. The Bluebook prefers N.C. Gen. Stat.
• Omitting the year on a statute. Leaving it off may work in practice, but for our Bluebook purposes, always include it. Statutes change, and the year tells the reader which version you used.

Parallel citations in North Carolina

A parallel citation shows more than one place to find the same case — typically the official reporter and an unofficial one. (A string citation, by contrast, cites more than one case.)

When to use them

Parallel cite when a court or supervisor tells you to, or when it's your workplace's convention. If you work for a North Carolina appellate judge, expect to use them: state rules require courts to. Many North Carolina lawyers use them routinely too. If you're not sure whether an assignment calls for parallel citations, ask the person who gave it to you — for this course, your RRWA professor.

How to write one

Give the two sources in this order:

1. The official reporter — N.C. (North Carolina Reports) for Supreme Court cases, or N.C. App. (North Carolina Court of Appeals Reports) for Court of Appeals cases.
2. West's unofficial regional reporter — the South Eastern Reporter: S.E., S.E.2d, or S.E.3d, depending on when the case was decided.

If you pinpoint, give a pinpoint page for each reporter.

No court appears in the parenthetical. The official reporter comes first, and it already tells the reader which court decided the case.

Short forms

Citing the immediately preceding authority (using id.)

Use id. for the official reporter, adding a pinpoint page only if that page has changed since the preceding citation. Then, after a comma, give the short form for the regional reporter — even if its page didn't change. (See B10.2 and Rule 10.9(b).)

Not citing the immediately preceding authority

When you can't use id., give the short form for the official reporter, a comma, then the short form for the regional reporter:

Case-name and institutional-author abbreviations

Table 6 is a list of words that you abbreviate in case names (and in the names of institutional authors). There's no need to memorize it — always check Table 6 in the Bluebook itself.

How it works

When a Table-6 word appears in a case name, you abbreviate it. That includes the first word of a party's name: Fed. Trade Comm'n v. Smith; Int'l Bus. Machs. Corp. v. Jones. The same words in your prose stay spelled out.

Common abbreviations

Here are some you'll run into often. Treat this as a sample, not a substitute for the table — always confirm against Table 6.

Plural and possessive forms

Table 6 lists the singular form of each word. When the word in the party's name is plural or possessive, adjust the abbreviation:

• Plurals: add an s to the abbreviation, unless Table 6 says otherwise. "Associations" → Ass'ns; "Departments" → Dep'ts; "Universities" → Univs.; "Machines" → Machs.
• Possessives: add an apostrophe and an s after the abbreviation. "Association's" → Ass'n's; "Commissioner's" → Comm'r's.

Punctuation inside abbreviations

Some abbreviations use an apostrophe (Ass'n, Nat'l, Gov't, Dep't) to mark a contracted middle. Others end with a period (Corp., Co., Inc.). Don't add an extra period when the abbreviation ends with one and falls at the end of a sentence — one period does the job.

Why the rule exists

Case names recur in every kind of legal writing. Abbreviating "International Business Machines Corporation" to Int'l Bus. Machs. Corp. every time saves space without losing the entity. Standard abbreviations also keep tables of authorities consistent — every brief in the case spells it the same way.

Common mistakes

• Leaving the first word of a party's name spelled out. Abbreviate it like any other Table-6 word: Int'l Bus. Machs. Corp., not International Bus. Machs. Corp.
• Inventing abbreviations not in Table 6. If a word isn't in the table, spell it out.
• Relying on memory. Check Table 6 every time you're unsure.
• Forgetting the apostrophe in Ass'n, Nat'l, etc.
• Abbreviating in prose. Table 6 governs case names, not regular writing.