B1.1
Citation sentences and citation clauses
A citation is its own little sentence — or a clause tucked inside one. Knowing which is which tells you where to put periods, commas, and how many citations you can stack.
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 sentence
The court rejected the qualified immunity defense. Harlow v. Fitzgerald, 457 U.S. 800, 818 (1982); Pearson v. Callahan, 555 U.S. 223, 236 (2009).
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.
Citation clause
The qualified immunity doctrine, see Harlow v. Fitzgerald, 457 U.S. 800 (1982), shields officials performing discretionary functions.
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. This is how the writer is precise without having to spell it out in prose.
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.
Quick check
B1.2
Introductory signals
A signal is a word or phrase before the citation that tells the reader exactly how the source supports your point. Pick the right one and you save the reader a lookup.
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.
Officers are entitled to qualified immunity unless they violate clearly established law. Harlow v. Fitzgerald, 457 U.S. 800, 818 (1982).
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.
See Harlow v. Fitzgerald, 457 U.S. 800, 818 (1982).
See also
Adds further support that is related to — but distinct from — what you have already cited. Almost always paired with a parenthetical explaining what it adds.
Cf.
The source supports the point by analogy. It's about something else, but the reasoning maps onto your proposition. Cf. almost always needs an explanatory parenthetical.
Compare … with …
Asks the reader to look at two (or more) authorities side-by-side because the comparison itself supports the point.
Contradicting signals: but see, but cf.
The mirror images. But see for sources that contradict the proposition directly; but cf. for sources that contradict it by analogy.
See generally
Background reading. Use sparingly, and always with a parenthetical, because the reader needs to know why the source is useful background.
Order and punctuation
If you use more than one signal, the Bluebook orders them — supportive signals first, comparison signals next, contradictory signals next, and background last. Signals are italicized, and a comma sets them off only when the signal is a phrase like see, e.g.,. Otherwise no comma after the signal.
Why the rule exists
Signals turn citations from a wall of cases into a small reading map. A careful reader can scan signals and instantly see which authorities are on point, which are by analogy, and which cut the other way.
Quick check
B1.3
Explanatory parentheticals
A parenthetical is the short phrase in parentheses after a citation that tells the reader what the case did or said. They are how you make a string cite earn its space.
What a parenthetical does
Parentheticals appear at the very end of the citation, after the year, and they generally begin with a present-participle verb (holding, noting, finding, rejecting) — never a capital letter, never a period.
Good
Harlow v. Fitzgerald, 457 U.S. 800, 818 (1982) (holding that government officials are shielded from liability unless they violate clearly established law).
Common error
Harlow v. Fitzgerald, 457 U.S. 800, 818 (1982) (The Court held that government officials are shielded from liability.).
When you need one
A parenthetical is strongly preferred after see also, cf., compare, but cf., and see generally. After no signal or after see, parentheticals are optional but often helpful.
How to write a good one
- Start with a verb in -ing: holding, concluding, rejecting, finding.
- Keep it short — one phrase that tells the reader why this case is here.
- If you must quote, keep it brief and inside the parenthetical's own quotation marks.
- If the parenthetical is a complete quoted sentence, it may begin with a capital and end with a period inside the parentheses. This is the exception, not the rule.
Why the rule exists
A reader will not chase every citation. A good parenthetical lets a busy reader trust your string cite without lifting a finger — and lets a careful reader skip straight to the cases that look promising.
B5.3
Modifying quotations and citations for clarity
Sometimes you have to change a quotation — to fit grammar, to drop irrelevant words, or to highlight a part. The Bluebook gives you a small set of marks that show the reader exactly what you changed.
Brackets for substitutions
Use square brackets when you change a letter, word, or short phrase inside the quotation — to fit your sentence, to clarify a pronoun, or to swap tense.
Original
"The defendant was negligent in his maintenance of the property."
As quoted in your brief
The court found that the defendant "[was] negligent in [the] maintenance of the property."
Ellipses for omissions
An ellipsis ( . . . — three periods, each separated by a space) shows the reader you dropped one or more words from the middle of a quotation. Don't use an ellipsis at the start of a quotation, and use it at the end only when the omitted text would have completed the quoted sentence.
The court reasoned that "the defendant . . . failed to take reasonable steps to prevent the harm."
Emphasis
If you italicize part of a quotation that wasn't italicized in the original, add a parenthetical at the end of the citation: (emphasis added). If the emphasis was already in the original, add (emphasis in original). If a previous citing court added the emphasis, use (alteration in original) or attribute it appropriately.
The court emphasized that "the defendant knew of the danger before the accident." Smith v. Jones, 100 F.3d 1, 4 (4th Cir. 1999) (emphasis added).
Citations within quotations
If the original source contained an internal citation that you are dropping, use (citation omitted). If you are dropping internal quotation marks, use (internal quotation marks omitted). When you keep them, the Bluebook uses single quotation marks inside doubles.
Why the rule exists
A quotation is evidence. Anything you change has to be visible at a glance, so a reader can decide whether your alteration was fair. Brackets, ellipses, and these short parentheticals are the audit trail.
Quick check
B10.1
The full case citation
Every full case citation is built from the same five parts. Once you can name them, the rest of B10 is just detail about each piece.
Anatomy
Brown v. Board of Education,
347 U.S. 483,
495
(1954).
Case name — italicized, party names separated by v.
Reporter citation — volume, reporter abbreviation, first page
Pinpoint page — the specific page being cited
Court & year — in parentheses; the court is omitted if the reporter makes it obvious
The five parts in order
- Case name — see B10.1.1.
- Reporter citation — volume number, reporter abbreviation, first page of the case. See B10.1.2.
- Pinpoint page(s) — the specific page(s) you are relying on. Always include one when you state a specific proposition.
- Parenthetical with court and year — see B10.1.3.
- (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.
B10.1.1
Case names
Italicize the case name; use the parties' names as they appear at the top of the opinion, then trim, abbreviate, and tidy according to a small set of rules.
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 are abbreviated per Table 10, but with one important twist: do not abbreviate "United States" when it is a party — write it out.
"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, search indexes, and across every brief in a case. Consistent treatment makes opinions findable and brief tables clean. The trimming rules keep citations short without losing the case's identity.
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.
B10.1.2
Reporters and pinpoint pages
The middle of a case citation tells the reader where the case lives. Volume, reporter, first page, pinpoint — in that order, with no period after the volume number.
The reporter sandwich
347
U.S.
483, 495
Reporter — the abbreviation for the published series
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 drop repeated digits: 483-89 (not 483-489).
- 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
This trips everyone up. 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
A reporter citation has to take a reader from "I trust your source" to "here it is on a shelf" with no ambiguity. The order — volume, reporter, page — matches how reporters are physically organized: pull the reporter, find the volume, open to the page.
B10.1.3
Court and year of decision
The last parenthetical of a full citation tells the reader which court decided the case and when. The rule is short, but easy to get wrong because the court is sometimes left out.
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 if the reporter already makes it clear.
When you omit the court
- U.S. Supreme Court — citing U.S., S. Ct., or L. Ed. implies the Court. Just give the year: (1982).
- A state's highest court — if the reporter is the state's official reporter (e.g., N.C.), the court is obvious. Just the year: (2010).
When you include the court
- Federal courts of appeals — always show the circuit: (4th Cir. 2018).
- Federal district courts — always show the district: (E.D.N.C. 2020), (S.D.N.Y. 2014).
- State intermediate appellate courts — show the court: (N.C. Ct. App. 2015).
- Regional reporters — if the case is in a regional reporter (S.E., S.E.2d), include the state and court because the reporter covers many states.
The year
The year is the year of decision. For cases that span years (argued one year, decided the next), use the decision year. The year sits at the end of the parenthetical, separated from the court by a space (no comma).
Examples
Harlow v. Fitzgerald, 457 U.S. 800 (1982).
Henson v. Santander Consumer USA Inc., 817 F.3d 131 (4th Cir. 2016).
State v. Smith, 362 N.C. 583 (2008).
State v. Jones, 240 N.C. App. 88 (2015).
United States v. Garcia, 412 F. Supp. 3d 580 (E.D.N.C. 2019).
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.
B10.2
Short-form citation
After you've cited a case in full once, you can use a short form. Two patterns: 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.
First (full) cite
Harlow v. Fitzgerald, 457 U.S. 800, 818 (1982).
Later (short) cite
Harlow, 457 U.S. at 820.
- Use the more distinctive party name. If the plaintiff is the government, the defendant's name is usually more useful: Smith, not United States.
- 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.
When to drop back to a full citation
If you haven't cited the case in the last five footnotes (or, in brief-writing practice, anywhere the reader might have lost track), use the full citation again — or at least include enough detail that the reader can find the case without scrolling.
Why the rule exists
Once you have introduced a case, repeating the full citation every time clutters the prose. The short form keeps the reading flow; id. goes a step further and tells the reader "still talking about the same source" without rewriting 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.
T1 · North Carolina
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 this reporter is the state's highest-court official reporter, you do not include the court in the parenthetical. Just the year.
State v. Lawrence, 365 N.C. 506, 510 (2012).
If a parallel regional citation is required (sometimes by local rule), add S.E.2d after the official cite: State v. Lawrence, 365 N.C. 506, 723 S.E.2d 326 (2012).
North Carolina Court of Appeals
The intermediate appellate court. Cite to N.C. App. (official reporter, the North Carolina Court of Appeals Reports). Because the reporter doesn't tell the reader which court decided the case on its own, include N.C. Ct. App. in the parenthetical along with the year.
State v. Hill, 240 N.C. App. 88, 92 (N.C. Ct. App. 2015).
Pay attention to the spelling: N.C. App. is the reporter; N.C. Ct. App. is the court abbreviation.
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.
N.C. Gen. Stat. § 14-72(a) (2023).
- Use the section symbol § for one section, §§ for a range or list.
- Cite by chapter and section: § 14-72 means Chapter 14, Section 72.
- The year is the year of the bound volume; if the section appears only in a supplement, cite (Supp. 2023).
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" plays out here in two different ways — N.C. omits the court, but N.C. App. requires the court abbreviation in the parenthetical.
Common mistakes
- Adding "(N.C. 2012)" to an N.C. cite — the reporter already implies 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. Statutes change; the year tells the reader which version you used.
T6
Case-name and institutional-author abbreviations
Table 6 is a short list of words that you abbreviate in case names (and in the names of institutional authors). Memorize the common ones; look up the rest.
How it works
When a Table-6 word appears in a case name, you abbreviate it. The same word in your prose stays spelled out. Words used as the first word of a party's name are not abbreviated unless the abbreviation is so common it would be more recognizable.
The ones you'll see constantly
Association → Ass'n
Brothers → Bros.
Company → Co.
Corporation → Corp.
Department → Dep't
District → Dist.
Division → Div.
Education → Educ.
Federal → Fed.
Government → Gov't
Incorporated → Inc.
Institute → Inst.
International → Int'l
Limited → Ltd.
Management → Mgmt.
National → Nat'l
Number → No.
Public → Pub.
Railroad → R.R.
Service → Serv.
Society → Soc'y
University → Univ.
The "first word" exception
If a Table-6 word is the first word of a party's name, do not abbreviate it — unless the entity is widely known by its abbreviation. So:
- "Federal Trade Commission" as a party → Federal Trade Comm'n v. Smith (don't abbreviate "Federal" as the first word).
- "International Business Machines" → International Bus. Machs. Corp. v. Jones (don't abbreviate "International" as the first word).
- But "FCC" is acceptable because the abbreviation is the entity's common name.
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
- Abbreviating a Table-6 word that appears as the first word of a party's name (other than the well-known-entity exception).
- Inventing abbreviations not in Table 6. If a word isn't in the table, spell it out.
- Forgetting the apostrophe in Ass'n, Nat'l, etc.
- Abbreviating in prose. Table 6 governs case names, not regular writing.
You've finished the lessons.
Now put it together. Try the practice set to drill one rule at a time, or jump straight to a full assessment.