Indigobook-2 0
Indigobook-2 0
SECOND EDITION
Status
This document, published on August 31, 2022, is the final release of Indigo Book 2.0, which
was first released in beta form on September 9, 2021. Errors and omissions may be sent to
[email protected].
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Statement of Nonaffiliation
NOT AUTHORIZED BY NOR IN ANY WAY AFFILIATED WITH: The Columbia Law
Review Association, Inc., The Harvard Law Review Association, the University of Pennsylvania
Law Review, The Yale Law Journal Company, Inc., or The Bluebook® A Uniform System of
Citation®.
Attribution
Cite as: The Indigo Book: A Manual of Legal Citation (Christopher Sprigman & Jennifer
Romig et al. eds., Public.Resource.Org 2d ed. 2021).
Formats
This document is available in HTML AND PDF formats.
0
Table of Contents
i
R5.1.2 Spans of pages................................................................................ 15
R5.1.3 Footnotes, figures, historical notes, and tables ............................16
R5.2 Sections, Subsections, and Related Subdivisions ....................................16
R5.2.1 Sections ..........................................................................................16
R5.2.2 Subsections .................................................................................... 17
R5.2.3 Spans of sections, subsections, and scattered subsections.......... 17
R5.3 Paragraphs ................................................................................................18
R6 Full and Short Citations ......................................................................................18
R6.1 Full Citations ...........................................................................................18
R6.2 Short Citations .........................................................................................18
R6.2.1 Short citations derived from the full citation ................................18
R6.2.2 Use of Id.........................................................................................19
R6.2.3 Use of supra ..................................................................................19
R7 Abbreviations ...................................................................................................... 20
R7.1 Abbreviations Generally .......................................................................... 20
R7.2 Ordinal Abbreviations in Citations...........................................................21
R7.3 Textual References .................................................................................. 22
R8 Quotations........................................................................................................... 23
R8.1 General Principles for Quotations ........................................................... 23
R8.1.1 Quotation marks........................................................................... 23
R8.1.2 Punctuation with quotations ....................................................... 23
R8.1.3 Citation placement ........................................................................ 23
R8.2 Alterations of Quotations ......................................................................... 24
R8.2.1 Omission of letters ....................................................................... 24
R8.2.2 Mistakes in the original quotation............................................... 24
R8.2.3 Substitution of letters or words .................................................. 24
R8.2.4 Use of parenthetical clauses to indicate changes to quotation .. 24
R8.2.5 Parentheticals to indicate quotations within quotations............ 25
R8.2.6 Unnecessary parentheticals ......................................................... 25
R8.3 Omissions in Quotations ......................................................................... 26
R8.3.1 Ellipses generally ......................................................................... 26
R8.3.2 Omission from the beginning of a quoted sentence..................... 26
R8.3.3 Omission in the middle of a sentence........................................... 27
R8.3.4 Omission Within a quotation as a phrase or clause ..................... 27
R8.3.5 Omission at the end of a sentence ................................................ 27
R8.3.6 Omission of a footnote or citation ................................................ 28
R8.3.7 Omission of full sentences following the quoted material .......... 28
R9 Block Quotations ............................................................................................... 29
ii
R9.1 Basic Form of a Block Quotation ............................................................. 29
R9.2 Formatting of Block Quotations .............................................................. 29
R10 Explanatory Parentheticals ............................................................................. 30
R10.1 Capitalization in Parentheticals ............................................................. 30
R10.1.1 Paraphrases and other original parentheticals............................ 30
R10.1.2 Quotations in parentheticals ....................................................... 30
R10.2 Format and Order of Parentheticals Showing the Weight of Authority
........................................................................................................................................... 31
B. CASES .......................................................................................................................... 32
R11 Full citation ....................................................................................................... 32
R11.1 Elements of a Full Citation ..................................................................... 32
R11.1.1 Parallel citation ............................................................................ 33
R11.1.2 Parentheticals .............................................................................. 33
R11.1.3 Prior or subsequent history of the case........................................ 34
R11.2 Case Names Italicized ........................................................................... 34
R11.3 Comprehensive Case-Name Abbreviations in Citation Sentences and
Clauses.............................................................................................................................. 34
R11.3.1 Common word abbreviations ...................................................... 34
R11.3.2 Geographical abbreviations (citation sentences and clauses)..... 35
R11.3.3 Discretionary abbreviations ........................................................ 35
R11.4 Limited Case-Name Abbreviations in Textual Sentences...................... 35
R11.5 General Case Name Truncation for All Contexts ................................... 36
R11.5.1 Surname ........................................................................................ 36
R11.5.2 First-named party on each side of the “v.” .................................. 37
R11.5.3 Commonly recognized abbreviations .......................................... 37
R11.5.4 Nicknames ................................................................................. 38
R11.5.5 Et al............................................................................................... 38
R11.5.6 Multiple business designations.................................................... 38
R11.5.8 United States as a party ............................................................... 39
R11.5.9 State or commonwealth as a party............................................... 39
R11.5.10 Municipalities ............................................................................. 40
R11.5.11 Prepositional phrases with locations .......................................... 40
R11.5.12 “The” ............................................................................................41
R11.5.13 Commissioner of Internal Revenue ............................................41
R11.5.14 Unions......................................................................................... 42
R11.5.15 Multiple dispositions .................................................................. 42
R11.5.16 Mandamus .................................................................................. 42
R11.5.17 Cases known by a distinct name ................................................ 42
iii
R11.6 Volume Number, Reporter, First Page................................................... 43
R11.6.1 Overview of volumes, reporters, and pages ................................. 43
R11.6.2 Reporter and series ...................................................................... 44
R11.6.3 Parallel citation in state court documents ................................... 45
R11.7 Pincites .................................................................................................... 45
R11.7.1 Multiple pages............................................................................... 46
R11.7.2 Span of pages................................................................................ 46
R11.7.3 Paragraph numbers in medium-neutral cases ............................ 46
R11.7.4 Citing a footnote ........................................................................... 47
R12 Court and Year .................................................................................................. 47
R12.1 Overview of Court and Year.................................................................... 47
R12.2 Court Abbreviations .............................................................................. 47
R12.3 Intermediate appellate departments or divisions.......................... 49
R12.3.1 General rule of omission .............................................................. 49
R12.3.2 Exceptions for including intermediate appellate department or
division .......................................................................................................................... 49
R12.3 Duplicative Court and Year Information ............................................. 49
R12.3.1 Court indicated by reporter ......................................................... 49
R12.3.2 Year indicated in medium-neutral citation................................. 49
R12.4 Special Note on Pending and Unreported or Unpublished Cases ....... 50
R12.4.1 Pending cases inLEXIS and Westlaw or other commercial
database ............................................................................................................................ 51
R12.4.2 Opinions only available online, but not in a commercial
database............................................................................................................................. 51
R13 Weight of Authority and Explanatory Parenthetical ....................................... 52
R13.1 Parenthetical for Weight of Authority................................................... 52
R13.2 Optional Explanatory Parenthetical ...................................................... 53
R14 History of the Case............................................................................................ 55
R14.1 Subsequent History ................................................................................ 55
R14.2 Required Explanatory Phrases .............................................................. 55
R14.2.1 Direct subsequent history of the litigation .................................. 55
R14.2.2 Indirect subsequent history and legislative or constitutional
subsequent history ............................................................................................................57
R14.3 Renamed Cases .......................................................................................57
R14.4 Enslaved Persons ................................................................................... 58
R15 Short Form Citation for Cases .......................................................................... 58
R15.1 Short Citations in Text............................................................................ 58
R15.2 Short Citations in Citation Sentences and Clauses ............................. 59
iv
R15.2.1 When a short form may be used .................................................. 59
R15.2.2 Form of short citations ................................................................ 59
R15.2.3 Exceptions to using the first party of the case name .................. 60
R15.2.4 Shortening party names .............................................................. 60
R15.3 Id............................................................................................................ 60
R15.3.1 Id. with immediately preceding citation (same page of case) ..... 60
R15.3.2 Id. with immediately preceding citation (different page)............61
R15.3.3 Id. forbidden with string citations and ambiguous references....61
C. STATUTES, RULES, REGULATIONS, AND OTHER LEGISLATIVE &
ADMINISTRATIVE MATERIALS ................................................................................... 63
R16 Federal Statutes ................................................................................................ 63
R16.1 Basic Citation Forms for Federal Statutes ............................................. 63
R16.1.1 United States Code ...................................................................... 63
R16.1.2 Year optional for current sections of the United States Code .......1
R16.1.3 Historical citations to the United States Code ............................ 64
R16.1.4 Unofficial annotated U.S. codes................................................... 64
R16.1.5 Year in unofficial U.S. code citations ........................................... 65
R16.1.6 Parallel citations to original section numbers............................. 65
R16.2 Short Citations ....................................................................................... 66
R17 State Statutes................................................................................................... 66
R17.1 Official State Codes ................................................................................. 66
R17.2 Forms of Citation to State Codes ........................................................... 67
R17.2.1 Basic citations to state codes........................................................ 67
R17.2.2 State codes by subject matter ...................................................... 67
R17.3 Year of State Code .................................................................................. 67
R17.4 Statutes Not in Force.............................................................................. 68
R17.5 Short Citations ....................................................................................... 68
R18 Rules of Procedure and Evidence, Restatements, and Uniform Acts ............. 68
R18.1 Rules of Evidence and Procedure........................................................... 68
R18.1.1 Federal and state rules ................................................................. 68
R18.1.2 Uniform rules ............................................................................... 69
R18.1.3 Abbreviations ............................................................................... 69
R18.2 Restatements, Model Rules, and Uniform Acts .................................... 69
R18.3 Uniform Commercial Code .................................................................... 71
R18.4 Other Uniform Laws and Similar Sources ............................................. 71
R19 Administrative Rules and Regulations............................................................. 71
R19.1 Federal Rules ........................................................................................... 71
R19.1.1 General format for administrative rules ....................................... 71
v
R19.1.2 C.F.R. parts.................................................................................... 71
R19.1.3 Optional name.............................................................................. 72
R19.2 State Regulations ................................................................................... 72
R19.3 Agency Adjudications, Arbitrations, Orders, and Other Actions.......... 72
R19.3.1 Adjudications .............................................................................. 72
R19.3.2 Arbitrations.................................................................................. 73
R19.3.3 Parallel citations .......................................................................... 73
R19.3.4 Pincites......................................................................................... 73
R19.4 Proposed Rules....................................................................................... 73
R19.5 Comments Filed with Agencies.............................................................. 74
R19.5.1 Comments generally..................................................................... 74
R19.5.2 Comments with subsequent agency response............................. 74
R20 Federal Taxation Materials ..............................................................................75
R20.1 Internal Revenue Code ...........................................................................75
R20.1.1 I.R.C.............................................................................................. 76
R20.1.2 Title 26 of the United States Code .............................................. 76
R20.1.3 Unofficial codes ........................................................................... 76
R20.2 Treasury Regulations............................................................................. 76
R20.3 Treasury Determinations ...................................................................... 76
R20.4 Private Letter Rulings.............................................................................77
R21 Legislative Materials.........................................................................................77
R21.1 Federal Bills and Resolutions..................................................................77
R21.2 Enacted Federal Bills and Resolutions .................................................. 78
R21.3 State Bills and Resolutions .................................................................... 78
R21.4 Committee Hearings .............................................................................. 79
R21.4.1 Congressional committee hearings.............................................. 79
R21.4.2 State committee hearings ............................................................ 79
R21.5 Federal Congressional Reports .............................................................. 80
R21.5.1 Report citations .......................................................................... 80
R21.5.2 Other legislative materials........................................................... 80
R22 Short Form Citation of Legislative and Administrative Materials.................. 80
R22.1 General short-citation forms................................................................ 80
R22.2 Id. ...........................................................................................................81
R23 Sources and Authorities: Constitutions............................................................81
R23.1 United States Constitution .....................................................................81
R23.3 State Constitutions .................................................................................81
R23.4 Short Forms ........................................................................................... 82
D. COURT & LITIGATION DOCUMENTS...................................................................... 83
vi
R24 Documents Filed in the Same Case................................................................. 83
R24.1 Document Title....................................................................................... 84
R24.2 Pincites to Page, Page and Line, or Paragraph .................................... 84
R24.2.1 Pincites to the appellate record ................................................. 84
R24.2.2 Page and line pincites ................................................................. 85
R24.2.3 Commas....................................................................................... 85
R24.3 Date of Document.................................................................................. 85
R24.4 Electronic Case Filing Number ............................................................. 85
R24.5 Parentheses or Brackets ........................................................................ 86
R25 Court or Litigation Documents from Other Cases........................................... 86
R25.1 General Format in Published Cases....................................................... 86
R25.2 Pending or Undecided Cases ................................................................. 87
R25.3 Oral Argument Audio and Transcripts.................................................. 87
R26 Short Form Citation for Court and Litigation Documents............................. 87
R27 Capitalization in Court Documents and Legal Memoranda............................ 88
R27.1 Capitalizing Court.................................................................................. 88
R27.2 Party Designations in a Litigation ......................................................... 88
R27.3 Titles of Court Documents ..................................................................... 89
R27.4 Types of Documents Not Capitalized .................................................... 89
E. BOOKS & NON-PERIODICALS .................................................................................. 90
R28 Full Citation for Books & Non-Periodicals ...................................................... 90
R28.1 General ................................................................................................... 90
R28.2 Author Name or Names......................................................................... 90
R28.2.1 Exact names................................................................................. 90
R28.2.2 Multiple authors.......................................................................... 90
R28.2.3 Title of the publication.................................................................91
R28.2.4 Pincite...........................................................................................91
R28.2.5 Edition, editor or translator, and year of publication .................91
R29 Short Form Citation for Books & Non-Periodicals.......................................... 92
R29.1 Id. ........................................................................................................... 92
R29.2 Supra ...................................................................................................... 92
F. JOURNALS, MAGAZINES, & NEWSPAPER ARTICLES ........................................... 94
R30 Full Citation for Journals, Magazines & Newspaper Articles ........................ 94
R30.1 Journal Citations................................................................................... 94
R30.1.1 Consecutively paginated journals (such as law reviews) ............ 94
R30.1.2 Journals and magazines with standard pagination .................... 94
R30.1.3 Pincites with standard pagination .............................................. 94
R30.1.3 Student-written material in law journals.................................... 94
vii
R30.2 Authors .................................................................................................. 95
R30.2.1 Name as listed ............................................................................. 95
R30.2.2 Two authors................................................................................. 95
R30.2.3 Multiple authors.......................................................................... 95
R30.2.4 No listed author .......................................................................... 96
R30.3 Journal Titles......................................................................................... 96
R30.3.1 Abbreviated titles......................................................................... 96
R30.2.2 Prepositions, articles, commas, and colons................................ 95
R30.2.3 Online supplements .................................................................... 95
R30.2.4 Evolving journal titles and series designation ........................... 96
R30.4 Newspaper Articles................................................................................ 97
R30.4.1 Print-based citation to newspaper article ................................... 97
R30.4.2 Citation to newspaper article online........................................... 97
R31 Short Form Citation for Journals, Magazines & Newspaper Articles ............. 97
R31.1 Id. .......................................................................................................... 97
R31.2 Supra..................................................................................................... 98
G. INTERNET SOURCES ................................................................................................ 99
R32 General Principles for Internet Sources ......................................................... 99
R32.1 Authenticated, Official, and Exact Copies ............................................. 99
R32.2 Print Sources Also Available on the Internet ........................................ 99
R32.3 Print Sources Reproduced on the Internet ........................................... 99
R32.4 Webpages and Internet Sources............................................................ 99
R33 Basic Formula for Internet Sources............................................................... 100
R33.1 Author Name(s).................................................................................... 100
R33.1.1 Personal author .......................................................................... 100
R33.1.2 Institutional authors .......................................................................... 101
R33.1.3 Forum authors ............................................................................ 101
R33.1.4 Unavailable author name ........................................................... 101
R33.2 Content Title ......................................................................................... 101
R33.2.1 Specific webpage title ................................................................. 101
R33.2.2 Shortened content title.............................................................. 102
R33.2.3 Comments and other related pages .......................................... 102
R33.3 Main Website Title............................................................................... 102
R33.3.1 Overall title ........................................................................................ 102
R33.3.2 Abbreviation .............................................................................. 102
R33.4 Pincite .................................................................................................. 103
R33.4.1 Paginated electronic publication, or publication of print
version ............................................................................................................................ 103
viii
R33.5 Date & Time ......................................................................................... 103
R33.5.1 Time not needed ........................................................................ 103
R33.5.2 Last visited................................................................................. 103
R33.6 URL ...................................................................................................... 104
R33.6.1 Entire URL preferred................................................................. 104
R33.6.2 ..................................................................................................... 104
R33.6.3 Archived URL ............................................................................ 104
R33.6.4 Multiple URLs ........................................................................... 104
R33.7 Social media ......................................................................................... 104
R34 Short Form Citations for Internet Sources ................................................... 105
H. TABLES ..................................................................................................................... 106
T1 Federal Materials ............................................................................................... 106
T1.1 Federal Judicial Materials..................................................................... 106
T1.2 Federal Statutory Materials..................................................................... 110
T2 Federal Administrative and Executive Materials............................................. 110
T3 U.S. States and Other Jurisdictions ..................................................................124
T4 Required Abbreviations for Services.................................................................216
T4.1 Service Publisher Names .........................................................................216
T4.2 Service Abbreviations .............................................................................216
T5 Required Abbreviations for Legislative Documents ........................................ 224
T6. Required Abbreviations for Treaty Sources..................................................... 225
T7. Required Abbreviations for Arbitral Reporters ............................................... 225
T8. Required Abbreviations for Intergovernmental Organizations ...................... 226
T9. Required Abbreviations for Court Names ....................................................... 226
T10. Required Abbreviations for Titles of Judges and Officials ............................ 230
T11. Required Abbreviations for Case Names in Citations, Periodical Titles, and
Institutional Authors (Common Words) ........................................................................231
T12. Required Abbreviations for Geographical Terms .......................................... 244
T12.1. U.S. States, Cities and Territories......................................................... 244
T12.2 Australian States and Canadian Provinces and Territories.................. 247
T12.3 Countries and Regions .......................................................................... 248
T13. Required Abbreviations for Document Subdivisions .................................... 257
T14. Required Abbreviations for Explanatory Phrases.......................................... 259
T15. Required Abbreviations for Institutional Names in Periodical Titles ............261
T16. Required Abbreviations for Publishing Terms .............................................. 264
T17. Required Abbreviations for Month Names .................................................... 265
T18. Abbreviations for Litigation Documents....................................................... 266
T19 Cross-References for Academic Legal Documents......................................... 269
ix
T20 Table of Citation Guides................................................................................ 272
T20.1 General Legal Citation Guides (Online).............................................. 272
T20.2 Country-Specific Citation Guides ........................................................ 273
I. CODICIL ..................................................................................................................... 274
J. ACKNOWLEDGMENTS ............................................................................................ 275
x
Introduction
Welcome to The Indigo Book 2.0—a free, Creative Commons-dedicated implementation of the
uniform system of citation commonly used in United States legal documents.
The Indigo Book (2d ed. 2021) isn’t the same as The Bluebook: A Uniform System of Citation
(21st ed. 2020), but it does implement the same system of citation that The Bluebook does. The
scope of The Indigo Book’s coverage is roughly equivalent to The Bluebook’s “Bluepages”—that
is, The Indigo Book covers legal citation for U.S. legal materials, as well as books, periodicals,
and Internet and other electronic resources. For the materials that it covers, anyone using The
Indigo Book will produce briefs, memoranda, law review articles, and other legal documents
with citations that are compatible with the Uniform System of Citation. Although law students,
scholars, and legal professionals sometimes talk about legal citation as if it is truly uniform, the
fact is that legal citation has never actually been a uniform national system. Accordingly, The
Indigo Book also provides insight into some of the discretionary preferences and jurisdiction-
specific variations found in legal citation throughout the United States.
Unlike The Bluebook and competitor citation manual The ALWD Guide to Legal Citation, The
Indigo Book is free, in two senses. The Indigo Book is given to you free of charge. The Indigo
Book is also free of the restrictions of copyright. You are free to copy and distribute this work,
and to improve on it. As with the 2016 version, we are releasing this version of The Indigo
Book under a Creative Commons “CC0” public domain dedication that allows you to use it,
copy it, distribute it, and modify it. The Indigo Book welcomes the Juris-M project for
automating legal citations, built in connection with the citation formats provided in the First
Edition of The Indigo Book and in progress with updates reflecting this Second Edition.
The first edition of The Indigo Book was compiled by a team of students at the New York
University School of Law, working under the direction of Professor Christopher Jon Sprigman
and published in 2016. The second edition of The Indigo Book was compiled by Professor
Jennifer Murphy Romig with assistance from students at the Emory University School of Law,
and published in beta form in 2021, with a final edition released in 2022. In the five years since
the first edition of The Indigo Book, U.S. citation practices have continued to expand and
fragment. The proliferation of citation formats has taken place via both official channels, such
as the North Carolina Supreme Court’s adoption of medium-neutral citation format; and
unofficial practices, such as the growing use of (cleaned up) as a parenthetical to replace
(internal citations and quotation marks omitted), as promoted by Washington, D.C. lawyer
Jack Metzler.
This Second Edition of The Indigo Book, like the first one, continues to take its inspiration
from the 10th edition of The Bluebook, published in 1959:
xi
The primary purpose of a citation is to facilitate finding and identifying the authority
cited. The rules set forth in this booklet should not be considered invariable. Whenever
clarity will be served, the citation form should be altered without hesitation; whenever
a citation would not amplify the identification of the authority referred to, no citation
should be given.
In that spirit, we hope you will take The Indigo Book, use it, enjoy it, and continue to improve
it.
xii
A. BACKGROUND RULES
A. BACKGROUND RULES
The Indigo Book states the rules and provides examples for standard legal documents.
We define standard legal documents as documents created for practical law-related
purposes such as court filings, legal memoranda, legal analysis, and other forms of
legal information that require or benefit from a technically precise and commonly
understood citation format. The legal citations for standard legal documents using The
Indigo Book adhere to a generally consistent national standard.
Many state courts and local legal communities use citation formats that vary from this
common standard, more so for state and local citations than for federal citations.
Table T3 provides selective information on state variations. In customizing legal
citations for a local audience, consult Table T3 as well as local court rules, customs,
and expertise.
1
The Indigo Book
sentences:
• Case names—in both full and short citations—and procedural phrases (such as In re
and Ex parte) embedded in the case names
• Book titles
• Article titles
• Certain titles in legislative materials such as committee hearings
• Introductory signals (examples: e.g., see, cf.,and accord)
• Explanatory phrases that introduce subsequent case history (examples: aff’d or cert.
denied)
• Cross references, (examples: infra, supra and id.)
• Words and phrases that introduce related authority (e.g., reprinted in and available in)
Example:
The Supreme Court’s practice of allowing modifications after opinions’ initial release
has at times extended beyond typographical corrections to substantive changes.
Richard Lazarus, The (Non)Finality of Supreme Court Opinions, 128 Harv. L. Rev.
540, 544 (2014).
Example:
As Adam Liptak reported in The New York Times, the Supreme Court sometimes
corrects and modifies its opinions after their initial release. Adam Liptak, Final Word
on U.S. Law Isn’t: Supreme Court Keeps Editing, N.Y. Times, May 25, 2014, at A1,
https://www.nytimes.com/2014/05/25/us/final-word-on-us-law-isnt-supreme-court
-keeps-editing.html.
2
A. BACKGROUND RULES
INDIGO INKLING
The typewriter was invented around the 1860s. The first edition of The Bluebook is from
1926. Typewriters of that era did not support italics or boldface. If you wanted to emphasize
text, your sole option was to underline. Throughout The Indigo Book, you'll see us
italicizing text rather than underlining, because that’s how we do it in the 21st Century. For
an archaic look or where local court rules require, underlining is a good option. If you have
a choice, we believe italics are easier to read and should be the preferred method.
While we’re on the subject of formatting text, we also urge writers to format their
quotations using all the benefits of modern word processing. Specifically, use well-
formatted “smart quotes” (shown here) that curl around the quoted material, rather than
"dumb quotes" (shown here) that are the same whether opening or closing a quote.
R3 In-Text Citations
• a clause within the sentence when the citation relates to a particular part of a sentence,
immediately following the claim it supports; or
Examples:
Under the due process requirement, there must be “some definite link, some
minimum connection, between a state and the person, property or transaction it seeks
to tax.” Miller Bros. Co. v. Maryland, 347 U.S. 340, 344-345 (1954).
Electronic signatures have the same legal effect as signatures signed with pen and ink.
3
The Indigo Book
Citations following sentences can be single citations or, when appropriate, several sequential
citations separated by a semicolon (known as a “string citation”). These string citations can
utilize citation signals consistent with Rule R4 to show the relationship of the citation to the
textual sentence.
Example:
Prior to 2018, Supreme Court precedent had required a seller to have a physical
presence within a state as a requirement of state taxation. See Quill Corp. v. North
Dakota, 504 U.S. 298 (1992); Nat’l Bellas Hess, Inc. v. Dep’t of Rev. of Ill., 386 U.S.
753 (1967).
Separate citation clauses from the text with commas. Do not add additional capital letters
beyond the required capitalization of the sources being cited.
Examples:
Federal law attempts to address online privacy generally, 18 U.S.C. §§ 2510-2523, and
children’s privacy specifically, 15 U.S.C. §§ 6501-6505.
Although detailed regulations apply to children’s privacy online, 16 C.F.R. pt. 312, significant
gaps remain in both federal and state law.
4
A. BACKGROUND RULES
Examples:
Since Nelson v. Sears, Roebuck & Co., 312 U.S. 359, 366 (1941), the Court has eschewed the
idea that a constitutional right could be grounded in “the practical opportunities for tax
avoidance.
In Nelson v. Sears, Roebuck & Co., the Court first eschewed the idea that a constitutional right
could be grounded in “the practical opportunities for tax avoidance.” 312 U.S. 359, 366 (1941),
The Children’s Online Privacy Protection Act of 1998, 15 U.S.C. §§ 6501-6505 (“COPPA”), was
the first federal law specifically protecting children under the age of 13.
INDIGO INKLING
Traditionally, the citations within standard legal documents have been integrated into the
main body text. These citations may be placed directly after textual sentences, in citation
sentences; as citation clauses within sentences; or textually embedded within sentences.
Traditionally, law review articles present their citation support via extensive footnotes in a
distinctive format with three different font styles (roman, italics, and Small Caps).
Some courts and lawyers are now producing standard legal documents using footnotes
rather than in-text citations. Legal scholar, speaker, and advocate Bryan A. Garner is the
best-known proponent of footnotes in standard legal documents, arguing that in-text
citations interfere with textual flow and disguise bad writing. Others such as Professor
Alexa Chew argue that in-text citations are superior because they integrate source
information into the text, a process that can be accomplished with style and grace. The
Indigo Book provides citation rules that can be used for either in-text or footnoted citations
in standard legal documents.
The original edition of The Indigo Book advised writers to use footnotes only when allowed
by a court’s local rules. This remains good advice, although we note that some writers use
footnotes when not expressly prohibited by a court’s local rules. Rule R3 has been modified
to more fully accommodate the writer’s discretion. As with many discretionary choices,
writers should select an approach based on the document’s purpose, audience, and overall
context.
5
The Indigo Book
R4 Signals
Category Signals
See
See also
Cf.
Signal for Compare <citation to source(s), separated with “and” if multiple> with
Comparison <citation to source(s), separated with “and” if multiple>
6
A. BACKGROUND RULES
general background.
In citation sentences, signals in the same category are listed within a single sentence, and each
one is marked off by semicolons. Signals in separate categories, however, are listed in separate
citation sentences.
Example:
Justice Scalia once noted that “the Constitution sometimes insulates the criminality of
a few in order to protect the privacy of us all.” Arizona v. Hicks, 480 U.S. 321, 329
(1987). But see Maryland v. King, 569 U.S. 435, 462-463 (2013) (acknowledging the
existence of “programmatic searches of either the public at large or a particular class of
regulated but otherwise law-abiding citizens” such as motorist checkpoints).
In citation clauses, all signals (regardless of category) are listed within a single citation
clause and separated by semicolons.
Example:
Justice Scalia once noted that “the Constitution sometimes insulates the criminality of
a few in order to protect the privacy of us all,” Arizona v. Hicks, 480 U.S. 321, 329
(1987); see also Maryland v. King, 569 U.S. 435, 481 (2013) (Scalia, J., dissenting)
(“Solving unsolved crimes is a noble objective, but it occupies a lower place in the
American pantheon of noble objectives than the protection of our people from
suspicionless law-enforcement searches.”); and later applied that principle to limit
police use of thermal imaging technology, see Kyllo v. United States, 389 U.S. 27
(2001); cf. United States v. Jones, 565 U.S. 400 (2012) (invalidating use of a GPS
tracking device for long-term surveillance).
INDIGO INKLING
String citations are not always desirable or appropriate, especially in standard legal
documents. Judge Ruggero J. Aldisert of the Third Circuit describes string citations as
“generally irritating and useless.” Alexa Chew, Stylish Legal Citation, 71 Ark. L. Rev. 823,
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858 n. 214 (2019) (quoting Judge Aldisert in Winning on Appeal: Better Briefs and Oral
Arguments 57 (2d ed. 2003). On the other hand, after a carefully crafted proposition drawn
from several authorities, a string cite may be “the right tool for the job.” Id. at 859.
When a string citation is appropriate, the writer must decide how to order the authorities in
the string. In relatively recent years, academic legal documents have followed an elaborate
hierarchy, which essentially consists of the following: constitutions before statutes, state
statutes in alphabetical order by state, federal cases before state cases, legislative materials
before regulatory materials, and all other primary materials, then followed by secondary
materials. See The Indigo Book: A Manual of Legal Citation Rule R10 (1st ed. 2016); The
Bluebook: A Uniform System of Citation Rule 1.4 (20th ed. 2015). This hierarchy often
does, in fact, provide the most logical order; it seems unwise to cite Wikipedia before the
United States Constitution, for example. But this hierarchy may not always fit the situation.
The Uniform System of Citation is evolving to encompass more flexibility and discretion in
a few pockets here and there, such as the basic principle that authorities cited in a string
within a single signal should be placed in a helpful and logical order.
Example:
Unbelievable as it may be, the Supreme Court has weighed in on the issue of whether a
tomato is a fruit or vegetable. See Nix v. Heden, 149 U.S. 304 (1893).
Example:
Even seemingly trivial issues, see, e.g., Nix v. Heden, 149 U.S. 304 (1893) (addressing
the question of whether tomatoes are fruits or vegetables), can sometimes merit input
from the Supreme Court.
8
A. BACKGROUND RULES
Example:
Example:
States are prohibited from “inflicting the penalty of death upon a prisoner who
is insane.” Ford v. Wainwright, 477 U.S. 399, 410 (1986).
Example:
In cases like Roper, Atkins, and Ford, the Supreme Court has established
certain classes of individuals upon which the death penalty may not be
imposed. Roper v. Simmons, 543 U.S. 551, 575 (2005); Atkins v. Virginia, 536
U.S. 304, 321 (2002); Ford v. Wainwright, 477 U.S. 399, 410 (1986).
R4.6.2 E.g.,
Use e.g., if the cited source is one of multiple sources to make the same assertion. The citation
may include however many sources the author finds to be helpful. Note that the comma in the
signal e.g., should not be italicized.
Examples:
In a criminal case, the state bears the burden of proving the defendant’s guilt beyond a
reasonable doubt. E.g., State v. Purrier, 336 P.3d 574, 576 (Or. Ct. App. 2014).
Prior to the Supreme Court’s decision in Riley v. California, 573 U.S. 373 (2014),
several circuits had generally allowed the police to conduct warrantless searches of cell
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phones of individuals under arrest. E.g., U.S. v. Murphy, 552 F.3d 405, 411 (4th Cir.
2009); U.S. v. Finley, 477 F.3d 250, 260 (5th Cir. 2007).
E.g., may also be used following any other signal, such as See or Contra in which case an
italicized comma should separate the two signals.
R4.6.3 Accord
Accord is used when more than one source substantiates a proposition, but the text quotes just
one of them. Use accord as the introductory signal for the non-quoted sources. Also, accord
may be used as the introductory signal for indicating that the law of one jurisdiction is
consistent with the law of another.
Examples:
Colorado law makes it the “duty of every corporation or person who has reasonable
grounds to believe that a crime has been committed to report promptly the suspected
crime to law enforcement authorities.” Colo. Rev. Stat. § 18-8-115 (2020); accord
Lunsford v. W. States Life Ins., 919 P.2d 899, 901 (Colo. App. 1996) (interpreting the
reasonable-grounds standard as lower than the probable-cause standard enabling
police to make a warrantless arrest).
Under Colorado law, witnesses have a limited duty to report crimes. Colo. Rev. Stat. §
18-8-115 (2020); accord Mass. Gen. Laws ch. 268, § 40 (2020).
R4.6.4 See
See is used when an authority does not directly state but clearly supports the proposition. See is
used instead of no signal when an inferential step is required to connect the proposition to the
authority cited.
Example:
Citizens have less training than police on detecting crime and no authority to detain
other individuals; thus, citizens’ duty to report crime is based on reasonable grounds
to believe a crime has been committed, rather than the more exacting probable cause
standard. See Lunsford v. W. States Life Ins., 919 P.2d 899, 901 (Colo. App. 1996)
(interpreting the reasonable-grounds standard to be less than the probable-cause
standard enabling police to make a warrantless arrest).
10
A. BACKGROUND RULES
See also is used for additional sources that support an assertion. Use see also when authority
that states or clearly supports the assertion has already been cited or discussed. The use of a
parenthetical is recommended with see also.
Example:
Slayer statutes prevent killers from reaping rewards from committing homicide.
Lunsford v. W. States Life Ins., 908 P.2d 79, 83 (Colo. 1995) (en banc); see also
Bennett v. Allstate Ins. Co., 722 A.2d 115, 117 (N.J. Super. Ct. App. Div. 1998)
(interpreting New Jersey’s slayer statute to mandate that “an intentional killer will not
be permitted to benefit, directly or indirectly, from his wrongful act”).
R4.6.6 Cf.
Cf. indicates support by analogy to the assertion. It may also be used where the source is
related but requires some interpretive work to connect to the assertion. Cf. may also be used
within a string citation to provide another source that is analogous to the previously cited
source in that string. Always use a parenthetical with cf. to explain the logical connection
required for the argument.
Examples:
Attorneys have an ethical duty of competence, but under Model Rule of Professional
Conduct 1.1 comment 3, that duty may be relaxed in emergency situations. Cf. Carter
v. Reese, 2016-Ohio-4559, 70 N.E.3d 478 (holding that Good Samaritan law protects
from liability anyone giving medical or nonmedical emergency aid, not only healthcare
workers providing medical aid).
See generally is used for useful background material. It is recommended that you use
a parenthetical with see generally in order to explain the authority’s relevance to the
proposition.
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Example:
The slayer rule is a product of common law principles prohibiting killers from
profiting their crimes. See generally Restatement (Third) of Restitution and Unjust
Enrichment § 45(2) (Am. L. Inst. 2011) (“A slayer's acquisition, enlargement, or
accelerated possession of an interest in property as a result of the victim's death
constitutes unjust enrichment that the slayer will not be allowed to retain.”).
Each portion of the compare … with … signal may contain multiple sources. Separate these
sources using commas and italicized and between the penultimate and ultimate citation in the
list.
Example:
The 20th Century saw sweeping changes in the definition and scope of the Due Process
Clause. Compare Lochner v. New York, 198 U.S. 45 (1905) (showing the Supreme
Court’s historical interpretation of the Due Process Clause as solely protecting an
individual’s right to contract), with McDonald v. Chicago, 561 U.S. 742 (2010)
(incorporating the Second Amendment using the Due Process Clause), BMW of North
America, Inc. v. Gore, 517 U.S. 559 (1996) (utilizing the Due Process Clause to reduce
punitive damages), and Dolan v. City of Tigard, 512 U.S. 374 (1994) (limiting the
zoning and ordinance powers of local governments under the Due Process Clause).
Insert a comma before with. As with all citation sentences, insert a period to conclude the
citation sentence. It is theoretically possible to conclude with a semicolon and continue with
more signals and citations in the order listed within this rule, but probably not advisable. See
our Indigo Inkling on string citations.
Contra is used when a cited authority directly conflicts with the proposition it follows.
12
A. BACKGROUND RULES
Examples:
The Bluebook efficiently formulates and expresses the rules of legal citation for a
variety of audiences. David Ziff, The Worst System of Citation Except for All the
Others, 66 J. Legal Educ. 668, 669 (2017) (reviewing The Bluebook: A Uniform
System of Citation (Columbia L. Rev. Ass’n et al. eds., 20th ed. 2015) (“Perhaps The
Bluebook survives because it’s not so terrible after all. Perhaps The Bluebook works
quite well for the task it was designed to perform.”). Contra Richard A. Posner, The
Bluebook Blues, 120 Yale L.J. 950, 951 (2011) (“It is a monstrous growth, remote from
the functional need for legal citation forms, that serves obscure needs of the legal
culture and its student subculture.”).
The Bluebook is a “monstrous growth, remote from the functional need for legal
citation forms.” Richard A. Posner, The Bluebook Blues, 120 Yale L.J. 950, 951 (2011).
Contra David Ziff, The Worst System of Citation Except for All the Others, 66 J. Legal
Educ. 668, 226 (2017) (reviewing The Bluebook: A Uniform System of Citation
(Columbia L. Rev. Ass’n et al. eds., 20th ed. 2015)) (“Perhaps The Bluebook survives
because it’s not so terrible after all. Perhaps The Bluebook works quite well for the task
it was designed to perform.”).
But see is used for authority that, while not directly contradicting the main proposition,
nonetheless clearly opposes it. But see is the opposite signal to see.
Example: The Supreme Court noted in Packingham v. North Carolina, 137 S. Ct.
1730 (2017), that the internet functions as a public square. But see Manhattan Cmty.
Access Corp. v. Halleck, 13o S. Ct. 1921 (2019) (holding that New York’s public access
television channel is not a state actor bound by the First Amendment).
Prepare yourself, and use this one sparingly: But cf. indicates that the cited source supports an
assertion that is similar to the opposite of the main assertion. It follows that But cf. is the
opposite signal to cf. indicating support by analogy. Always use a parenthetical with but cf. to
explain the logical connection required for the argument. This is the weakest signal for
contrary authority.
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Example: The bar exam is the only professional-licensure exam that bears so little
relationship to the education that precedes it or the professional work that follows it.
But cf. Michael Riscica, Why (Smart & Talented) People Fail the Architect Exam,
Architizer, https://architizer.com/blog/practice/details/5-reasons-why-smart-and-
talented-people-fail-the-architect-exam/ (last visited June 1, 2021) (“There is no
correlation between success in architecture school and success with completing the
exam. In fact, I truly believe that the creativity that brought you success in architecture
school will be your biggest handicap with studying for the [architecture registration
exam].”)
R5.1 Pages
A legal citation usually refers not only to a source in general, but to specific points within that
source—whether a page, a footnote on a page, a section or sub-section, or a numbered
paragraph. Citations must include specific reference to the point within the source being
referred to. For cases, these specific references are known as pincites.
Refer to the source’s page by its number or numbers. Do not use p. or pp. to indicate a page
reference. Use “at” if needed for clarity.”
Examples:
The Supreme Court held that a state cannot copyright its official annotated code
because “whatever work that judge or legislator produces in the course of his judicial
or legislative duties is not copyrightable” Georgia v. Public.Resource.org, Inc., 140 S.
Ct. 1498, 1513 (2020).
Elizabeth Porter & Kathryn Watts, Visual Rulemaking, 91 N.Y.U. L. Rev. 1183, 1240
(2016).
Anjali Vats, The Color of Creatorship: Intellectual Property, Race, and the Making of
Americans 35 (2020).
14
A. BACKGROUND RULES
Refer to a span of pages with a hyphen (-), an en dash (–), or the word “to” if needed for clarity.
Note that an en dash is the proper standard for providing a span of pages in a formal legal
publication, but hyphens are commonly used in practice. Drop all digits except the last two,
unless needed for clarity.
Examples:
Elizabeth Porter & Kathryn Watts, Visual Rulemaking, 91 N.Y.U. L. Rev. 1183, 1240-41
(2016).
Selmon v. Hasbro Bradley, Inc., 669 F. Supp. 1267, 1272-73 (S.D.N.Y. 1987).
INDIGO INKLING
Hyphens, en dashes, and em dashes are three separate marks with mostly separate
functions in citations and sentences. These marks all comprise short, horizontal lines
that—with the help of glasses and/or a magnifying glass—you will see have microscopically
varying lengths.
Hyphens (shortest in length) are used for phrasal adjectives (e.g., “laser-sharp focus,”
“larger-than-life character,” and compound words (e.g., “daughter-in-law,” “over-the-
counter”). Hyphens are also a feature of many statutory citation formats, such as Ala. Code
§ 27-14-24 and O.C.G.A. § 33-24-41. Meticulously preserve hyphens when they are
intrinsically part of a citation, such as 42 U.S.C. § 2000e-2(a)(1). Hyphens are commonly
used for page ranges in standard legal documents.
En dashes (longer than hyphens, shorter than em dashes) can be used for ranges of values
(e.g., page ranges) and contrasting or connected pairs of words (e.g., Sarbanes–Oxley Act),
especially in academic legal documents.
Em dashes (longest in length) are used for inserting a break in a thought; isolating a
concluding phrase; setting on a parenthetical explanation or amplification; and signaling a
collection of ideas. Here’s one example: “When her new Volkswagen was finally
delivered—nearly three months after it was ordered and following the revelation of VW's
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massive scheme of emissions control fraud—Alice decided she didn't want it.”
Cite a footnote on a page by providing the page, one space, the abbreviation “n.”, and the
footnote number. Follow the same format for figures, historical notes, tables, and similar
features. Refer to Table T13 for abbreviations such as “fig.” for “figure.” Do not add a space
between the abbreviation and the number or letter designating the figure, footnote, historical
note, or table.
Examples:
Elizabeth Porter & Kathryn Watts, Visual Rulemaking, 91 N.Y.U. L. Rev. 1183, 1239
n.270 (2016).
Cunningham v. State, 822 S.E.2d 281, 285 n.4 (Ga. 2018) (Hunstein, J.) (“And that’s
all she wrote.”).
U.S. v. Rentz, 777 F.3d 1105, 1110 fig. (10th Cir. 2015) (Gorsuch, J.) (diagramming 18
U.S.C. § 924(c)).
Cite a section with the section symbol (§) followed by a space and the section number.
Examples:
21 U.S.C. § 343.
INDIGO INKLING
The symbol “§” means “section,” and “§§” is the plural form. The section symbol can be
inserted as a special character. Computer-keyboard shortcuts create the § symbol with just
a few key strokes: [Option-6] on an Apple keyboard or [Alt-0167] on a Windows keyboard
using the numeric keypad. Setting up a customized keyboard shortcut may be a good option
16
A. BACKGROUND RULES
for Windows users who generate legal citations on a regular basis. If using a mobile device,
you may be able to insert a section into text such as by tapping and holding the “&” key.
R5.2.2 Subsections
Specifically cite a subsection using the punctuation in the original source, and using the
original capitalization style. Do not remove or alter parentheses or hyphens or dashes in the
original source’s citation.
Examples:
42 U.S.C. § 2000ff–5(a).
42 U.S.C. § 2000ff–1(b)(2)(A).
42 U.S.C. § 2000ff(2).
Use a hyphen, en dash (–), or the word “to” to indicate a span of sections or subsections. In a
span or collection of scattered sections, include the last portion of a citation and omit the
identical first part, unless repetition of all portions is needed for clarity. Do not use “et seq.” for
a span of sources.
Examples:
18 U.S.C. §§ 3681-82.
Use the source’s formal title for a collected span of sections, such as parts in the Code of
Federal Regulations. Table T13 provides the abbreviation for the subdivision “Part.”
Example:
17
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Example:
N.Y. Comp. Codes R. & Regs. tit. 16, §§ 895.1(f), 897.1(b) (2021).
R5.3 Paragraphs
Sources organized into formal paragraphs should be cited with specific reference to the
paragraph referred to in the cited proposition. Do not use “at” with ¶ citations.
Examples:
Short-form citations enable various sources to be used throughout a passage without repeating
the entire full citation every time. Short-form citations generally identify the source and
pincite, using a form that follows from the full citation form, while not repeating every detail
from the full citation.
Every full citation has at least one short form that can be used later in a document after the
initial full citation. Refer to the source-specific rules in the Indigo Book for short-citation form
examples of each source.
18
A. BACKGROUND RULES
Use the short form Id. (capitalized in a citation sentence after a text sentence) or id.
(uncapitalized within a sentence as citation clause) to support a statement where it refers to the
same exact source cited in the immediately preceding citation. Id. can be used for statutes,
regulations, cases, and most other sources.
Id. can be used alone, to indicate the same page of the same source. It can be used with a new
pincite to a page, section, or other subdivision, to indicate a different portion of the
immediately preceding source. Id. can also refer to a preceding citation that is itself Id. or
another short form of a citation. Use “at” to indicate a pincite to a page. Do not use “at” with Id.
followed by a section or paragraph pincite.
Id. at 1512.
Id. § 9.
Id. ¶ 12.
In general, do not use id. if it causes confusion or does not save space. For example, id. cannot
be used after a string citation, even to refer to the final source listed in that string. Do not use
id. to refer to appellate-record citations such as R. at 2. It may be used for sources with longer
names in litigation documents, so long as the reference remains clear.
Id. can be used in either in-text citations or footnotes. Id. is typically not used more than four
times sequentially in footnotes.
Supra may be used as part of a short-form citation with secondary sources such as books,
periodicals, internet sources. Legislative hearings may be referred to with supra. Do not use
supra with primary sources such as cases, statutes, constitutions, and most legislative
materials (hearings excepted). Also do not use supra with Restatements, model codes, or
regulations.
Apart from its use in selected legal citations, supra may also be used as an internal cross
reference.
Examples:
Full citation:
Anjali Vats, The Color of Creatorship: Intellectual Property, Race, and the Making of
Americans (2020).
19
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INDIGO INKLING
In academic legal documents using footnotes, a “preceding five” norm has developed
wherein one may continue to use a short form citation as long as the full citation appears in
one of the previous five footnotes.
There has been some variation in the application of this rule; for example, some
practitioners will continue to use the short form throughout an entire article or brief unless
they need to use “id.” repeatedly, in which event they follow the “preceding five” rule to
avoid potential ambiguity. However, none of these conventions are absolute. Short-citation
forms should be used in a clear, consistent, and helpful manner.
R7 Abbreviations
• Table T1, Table T2, and Table T3 provide information and abbreviations relevant to
federal and state primary-source citations.
• Table T4 provides abbreviation for looseleaf services compiling cases and other legal
sources in frequently updated topical collections.
• Table T5 provides legislative abbreviations.
• Tables T6, T7, and T8 provide abbreviations for international, treaty, and arbitration
sources.
• Table T9 and Table T10 provide abbreviations for specific types of U.S. courts and the
titles of judges and officials.
• Table T11 is of particular interest to many law students and others grappling with cases
and periodical citations. It provides common-word abbreviations used in case names
and for institutional authors and periodical titles. Table T12 provides geographical
20
A. BACKGROUND RULES
abbreviations.
• Table T13 provides abbreviations for document subdivisions, and Table T14 provides
abbreviations for explanatory phrases.
• Table T15 provides abbreviations for specific institutional names in periodical titles,
and thus these abbreviations take precedence over any conflicting common-word
abbreviations for institutional names from Table T12. For example, the American Bar
Association is ABA, not Amer. Bar. Ass’n, when used as an institutional author.
• Table T16 provides abbreviations for publishing terms such as editor and translator.
Table T17 provides abbreviations for the months of the year, needed in some periodical
citations and in slip-opinion citations and other cases found online rather than in
reporters (thus requiring exact dates).
• Table T18 is new to the Second Edition of The Indigo Book and provides abbreviations
for litigation documents such as citing an affidavit or petition for certiorari.
• Table T19 is also new and shows selective examples of how the Uniform System of
Citation produces citations in standard and academic formats—in other words, a guide
to converting the practical citations in The Indigo Book into a citation for an academic
legal document (a law review). This Table is certainly not comprehensive but provides a
quick view into the font differences within the two branches of the Uniform System of
Citation.
• Finally, Table T20 provides selective citations to additional online citation guides.
Examples:
1st Dist.
2d Cir.
2d ed.
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3d Dist.
4th Cir.
Incorrect:
4th Cir.
5th Dist.
F. Supp. 2d
F.3d
F.4th
Do not abbreviate the ordinal in a citation to the Restatement either in textual sentences or
citations:
When not providing a precise citation at all, but referring to a court in a textual sentence, spell
out the court’s name consistent with common practice. See Rule R27 on capitalizing “Court” in
court documents and legal memoranda.)
Example:
The Florida Supreme Court overruled the Fourth District Court of Appeal’s previous
holding on judges’ use of Facebook.
22
A. BACKGROUND RULES
R8 Quotations
Quotations of 49 words or less should be designated with double quotation marks that open
and close the quotation. Do not use quotation marks around block quotations (see Rule R9 for
block quotations.)
Examples:
The Court of Appeals affirmed the dismissal of a consumer-deception claim against a legal
publisher: “Under the circumstances, plaintiffs, or any reasonable consumer, could not have
been materially misled to believe that defendant guaranteed Part III of the Tanbook was
complete and accurate at any given time.”
The court ruled that “a consumer acting reasonably under the circumstances here would not
have believed that defendant represented that the section at issue, containing rent control
statutes and regulations, was current and accurate for its one-year shelf life.”
Punctuation that is part of the quoted text should appear inside the quotation marks. When the
quotation is embedded into the sentence using a comma or a period added by the writer at the
end of the quotation, that comma or period also appears inside the quotation marks (even
though it is not part of the actual quoted text from the source). Punctuation added to a
quotation anywhere other than at the end of the quoted material is an alteration that should be
indicated with brackets.
Examples:
Given that legal professionals are “merely a subclass of consumers,” New York’s
consumer deception law does apply to them.
Insert a citation sentence for the quoted material after the end of the sentence. Insert the
citation as a clause if needed for clarity about which portion of the sentence is attributable to
the source. Citations can be full citations or short citations, as appropriate to the surrounding
context.
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Examples:
“[A]nnotations published by legislators alongside the statutory text fall within the
work legislators perform in their capacity as legislators.” Georgia v.
Public.Resource.org, 140 S. Ct. 1498, 1509 (2020).
The Supreme Court overruled prior precedent about online retailing in light of “the
day-to-day functions of marketing and distribution in the modern economy,” Wayfair
v. South Dakota, 138 S. Ct. 2080, 2094 (2018), but has not applied similar reasoning
to jettison other precedent.
Place an empty bracket at the end of a common root word to indicate the change.
Example:
To acknowledge a significant mistake in the original quotation, keep the problematic word or
phrase and follow it with [sic] to indicate this to the reader.
Example:
Any substitutions into quoted material should be bracketed. This includes words which might
add clarity and context, and changes to the capitalization of letters
Example:
Use the following phrases attached to a legal citation following a quotation, to indicate changes
24
A. BACKGROUND RULES
• (emphasis added)
• (alteration in original)
• (citation omitted)
• (emphasis omitted)
• (internal quotation marks omitted)
• (footnote omitted)
When using a quotation within a quotation, you can either (1) attribute it to the original source
with a parenthetical, or (2) acknowledge it by signaling that its citation has been omitted.
Examples:
Just as the Supreme Court has held that an official statement of the case, syllabus, or
headnote prepared by judges “fall within the ‘work they perform in their capacity as
judges,’ so too annotations published by legislators alongside the statutory text fall
within the work legislators perform in their capacity as legislators.” Georgia v.
Public.Resource.org, 140 S. Ct. 1498, 1509 (2020) (quoting Banks v. Manchester, 128
U.S. 244, 253 (1888)).
“Although the annotations are not enacted into law through bicameralism and
presentment, the Commission's preparation of the annotations is under Georgia law
an act of ‘legislative authority,’ and the annotations provide commentary and
resources that the legislature has deemed relevant to understanding its laws.” Id.
(citation omitted).
• (emphasis in original)
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INDIGO INKLING
Dealing with quoted material can be minutely technical, as with parentheticals such as
(citation omitted, internal quotation marks removed, and second emphasis omitted). To
simplify and streamline citations and replace the granular detail of such parentheticals,
attorney Jack Metzler has proposed and promoted a shorter parenthetical to handle such
situations: (cleaned up). The parenthetical (cleaned up) after a quotation and citation
indicates essentially that the writer has adjusted the citation’s mechanics to the situation
and will not list and elaborate on each mechanical modification, but is indicating to the
reader that small tweaks have been made for clarity and convenience.
The (cleaned up) parenthetical has not become part of the Uniform System of Citation—yet.
It has, however, actually been used in thousands of federal and state judicial opinions. See
Jack Metzler, Cleaning Up Citations, 18 J. App. Prac. & Process 142 (2017). The (cleaned
up) approach is not without its critics, though, who argue that transparently meticulous
care with quotations enhances the writer’s credibility and does not unduly distract readers.
Writers will need to make individual decisions whether to consider (cleaned up), depending
on their role and their audience. Apart from these individual decisions, the (cleaned up)
parenthetical provides yet more evidence that legal citation can and does evolve not just
through the periodic publication of citation rules but through practice and dialogue within
the legal community.
The ellipsis in legal writing is represented by three periods and four spaces.
Insert a space after the last letter of the preceding phrase, a space between each period, and a
space before the first letter of the following phrase. Rules R8.3.2-R8.3.7 contain rules and
examples for incorporating ellipses in various situations.
When omitting the beginning of a quoted sentence, do not use an ellipsis. Instead, capitalize
the first letter and place it in brackets. If the first letter of the quoted material is already
capitalized, no change is needed, but—as with all quotes—ensure that the quotation is accurate
in context.
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A. BACKGROUND RULES
Example:
When omitting the middle of a quoted sentence, insert an ellipsis to indicate the omission.
Example:
“The difference between actual and red flag knowledge is . . . between a subjective and
an objective standard.”
If there is an omission within the quotation, mark the omission with an ellipsis.
Example:
Exxon Mobil Corp. v. Allapattah Servs., Inc., 545 U.S. 546, 571 (2005) (noting that
“[t]he distinguished jurists who drafted the Subcommittee Working Paper . . . agree
that this provision, on its face, overrules Zahn.”).
When omitting the end of a quoted sentence, insert an ellipsis between the last letter quoted
and the punctuation mark of the original quote.
Example:
“The difference between actual and red flag knowledge is thus not between specific
and generalized knowledge . . . .”
When omitting material at the end of one sentence and the beginning of the next sentence, use
one ellipsis to mark the omission but include the final punctuation mark of the first sentence as
well as bracket and capitalize the first letter of the following sentence.
Example:
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“The difference between actual and red flag knowledge is thus not between specific
and generalized knowledge . . . . [T]he red flag provision turns on whether the provider
was subjectively aware of facts that would have made the specific infringement
objectively obvious to a reasonable person.”
When omitting a footnote or citation from quoted material, do not insert an ellipsis. Do insert a
parenthetical indicating the omission immediately after the citation to the quoted source. See
Rule R8.2.6.
When omitting material following a final punctuation mark, do not use an ellipsis.
Example:
“The difference between actual and red flag knowledge is thus not between specific
and generalized knowledge, but instead between a subjective and an objective
standard.”
INDIGO INKLING
The ellipsis is traditionally made with four spaces and three periods . . . but computers have
keyboard shortcuts to produce an ellipsis that constitutes one single character. For
example, option-semicolon on an Apple keyboard produces … as its ellipsis shortcut. While
the ellipsis shortcut character is not officially sanctioned in any citation manual, some
practitioners use it freely in court filings.
28
A. BACKGROUND RULES
R9 Block Quotations
Set off quotations consisting of 50+ words into a block quotation, followed by the
citation if not apparent from the introduction to the block quotation:
Example:
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redundant. (Exception: Use quotation marks if the entire block quotation is itself a
quotation within the source being quoted, and indicate the internal quotation and
source parenthetically after the block.)
• In general, internal quotation marks should appear as in the original.
• The citation following a block quotation should start at the line’s left margin, without
any indentation. This citation can be a full citation or a short citation, as the
circumstances dictate. It should include a pincite to the page or pages where the quoted
material is found.
If not quoting the authority, do not begin an explanatory parenthetical with capital letter.
Example:
Dr. Seuss Enters., L.P. v. Penguin Books USA, Inc., 109 F.3d 1394 (9th Cir. 1997)
(holding that publisher’s asserted parody of O.J. Simpson murder trial was
substantially similar to copyrighted work).
If quoting the authority, only begin parenthetical with capital letter and end with a period
when the parenthetical quoted is or reads as a complete sentence.
Example:
See Ty, Inc. v. Publ’ns Int’l Ltd., 292 F.3d 512, 520 (7th Cir. 2002) (“[T]he shortage
that creates the secondary market stampedes children into nagging their parents to
buy them the latest Beanie Babies, lest they be humiliated by not possessing the
Beanie Babies that their peers possess.”).
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A. BACKGROUND RULES
The source-related parentheticals are followed by the explanatory parenthetical, if any; and
last, the prior or subsequent history (see Rule R14) as shown in this order of parenthetical
types:
(date) [hereinafter <short name>] (en banc) (<Lastname, J.>, concurring) (plurality
opinion) (per curiam) (alteration in original) (emphasis added) (footnote omitted)
(citations omitted) (quoting <another source>) (internal quotation marks omitted)
(citing <another source>), http://www.domainname.com (explanatory parenthetical),
prior or subsequent history.
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B. CASES
INDIGO INKLING
The format of traditional case citations derives from the historical print publication of
bound reporters, such as West’s National Reporter System. The citation elements are based
on the reporter’s volume number, title of the reporter including series number, and first
page of the cited case. In June 2021, the famous reporter of federal appellate cases, the
Federal Reporter, 3d published its last volume, turning over to the first volume of a new
series, the Federal Reporter, 4th. Citations for federal appellate cases decided in the latter
half of 2021 and beyond will be assigned citations along the lines of 123 F.4th 456. The
Federal Reporter, 3d is a set of books for sale by West Publishing, and Federal Reporter, 4th
no doubt will be as well. Most researchers do not lay their hands on these books, much less
purchase them; still, the elements of traditional case citation derive directly from the West
publication system.
Starting in the early 1990s, some states began adopting public-domain citations, also
known as neutral citations, vendor-neutral citations, medium-neutral citations, and
universal citations, because they do not rely on specific proprietary bound publications. A
medium-neutral citation looks something like this: These states are shown in Table T3. The
Indigo Book encourages the use of public domain citations. When giving a public domain
citation, also include a parallel citation to the appropriate print reporter if possible. For
example: Curlee by and through Becerra v. Johnson, 2021-NCSC-32, 856 S.E.2d 478.
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B. CASES
Case citations may also include the additional components such as a signal, subsequent history,
parallel citations, and explanatory parentheticals. These additional components are sometimes
required and sometimes discretionary, as determined by the case’s characteristics, the way the
citation supports the text, applicable court rules, or other audience expectations.
Examples (federal):
Examples (state):
Mercer Univ. v. Stofer, 841 S.E.2d 224 (Ga. Ct. App. 2020).
A case citation may also include parallel citation to another print reporter or online location for
the case, such as a medium-neutral citation. When the print reporter unambiguously indicates
the identity of the court, omit the court from duplication at the end of the citation. When the
medium-neutral citation unambiguously indicates the court and year, either or both elements
may be omitted from further duplication at the end of the citation.
Examples:
Mercer Univ. v. Stofer, 306 Ga. 191, 830 S.E.2d 169 (2019).
State ex rel. Pilarczyk v. Geauga Cty., 2019-Ohio-2880, 157 Ohio St. 3d 191, 134 N.E.3d 142.
R11.1.2 Parentheticals
A case citation may also include one or more parentheticals after the main citation elements.
Parentheticals, if any, ordered according to the following functions: (indicating the weight of
authority such as en banc) (indicating the source of a quotation or cited assertion in the main
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Examples:
Barking Hound Village, LLC v. Monyak, 787 S.E.2d 191, 198 (Ga. 2016) (“the unique human-
animal bond, while cherished, is beyond legal measure”).
Toolson v. N.Y. Yankees, Inc., 346 U.S. 356 (1953) (per curiam) (affirming baseball’s
exemption from the scope of federal antitrust laws).
A case citation may also include prior or subsequent history, if required by Rule R14.
Example:
Leonard v. Pepsico, Inc., 88 F. Supp. 2d 116, 127 (S.D.N.Y. 1999), aff’d, 210 F.3d 88 (2d Cir.
2000) (per curiam).
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B. CASES
If the resulting abbreviation is not ambiguous, words of eight or more letters may be
abbreviated to save substantial space in citation sentences and clauses. As a guide, remember
that citation sentences and clauses stand apart from the prose text they support, and thus can
prioritize efficiency over readability; but clarity and preciseness are still important factors.
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Abbreviation Word
& and
Ass’n Association
Bros. Brothers
Co. Company
Corp. Corporation
Inc. Incorporated
Ltd. Limited
No. Number
Example:
In McDonnell Douglas Corp. v. Green, the Supreme Court held that in a disparate
treatment case, the plaintiff bears the initial burden of establishing a prima facie case
of employment discrimination. 411 U.S. 792 (1973).
Example:
R11.5.1 Surname
When referring to a case with an individual’s name in the case name, use the person’s full
family name (i.e., their surname). Delete first name and initials, except when the full name of
the person is in a language that lists the surname first, or when referring to the name of a
business or where the court has abbreviated the party’s surname (as is common in cases
involving minor children as parties).
36
B. CASES
Examples:
Smith v. Jones
Xu Lanting v. Wong
Luke S. v. Leia S.
Only include the surname of the first-listed party of the plaintiffs and the surname of the first-
listed party of the defendants. Do not use “et al.” to indicate omitted additional parties.
Abbreviate commonly recognized agencies and organizations by their initials, such as the SEC
and the ACLU.
Examples:
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credible journalism as a gauge of what is commonly known. For example, the New York
Times abbreviates Environmental Protection Agency as EPA but does not abbreviate Fish
and Wildlife Services as FWS. Another test is to informally survey at a handful of recent
cases. For example, PETA and the USDA are used in case names, suggesting that they are
commonly recognized, at least for legal-citation purposes.
But don’t overdo it with the acronyms; keep in mind the scolding Judge Silberman issued in
a case before the United States Court of Appeals for the District of Columbia Circuit: “The
use of obscure acronyms, sometimes those made up for a particular case, is an aggravating
development of the last twenty years.” Delaware Riverkeeper Network v. FERC, 753 F.3d
1304, 1321 (D.C. Cir. 2014) (Silberman, J., concurring). With this judge’s aggravation in
mind, use only those abbreviations and acronyms that are easy to understand and make the
reader’s work easier.
R11.5.4 Nicknames
R11.5.5 Et al.
Do not add “et al.” to indicate the omission of other parties not listed. Delete “et al.” even if
used in a case caption indicating multiple parties.
Omit terms such as “L.L.C.” and “Inc.” that indicate the party is a business when that fact is
made clear because the party name includes a word such as “Co.” or “Inc.”
When you see “on the relation of,” “on behalf of,” and similar expressions, replace with “ex rel.”
38
B. CASES
When you see “in the matter of,” “petition of,” and similar expressions, replace with “In re.”
Bankruptcy cases sometimes contain multiple case names including both a procedurally based
name with “In re” and an adversary case name. In such cases, use the adversary case name
followed parenthetically in the case name with the procedurally based name:
Example: Farmers Cooperative Co. v. Ernst & Young, Inc. (In re Big Sky Farms Inc.)
In non-bankruptcy cases, do not use “In re” when the case name also contains the name of an
adversary; use the adversary name.
Spell out “United States” when it is a named party. Omit “of America.”
Note that “United States” may be abbreviated as “U.S.” when used as an adjective for an
agency, in citation sentences and clauses.
Omit “People of,” “State of,” and “Commonwealth of,” unless citing a court located in that state,
in which case retain only “People,” “State,” or “Commonwealth.”
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R11.5.10 Municipalities
Include phrases such as “Town of” and “City of” when such phrases are the first part of the
name of a party. Omit phrases such as “Town of” and “City of” if the phrase appears in the
middle or end of the name of a party.
Include prepositional phrases indicating location after a municipal category such as “City of” or
“Town of.”
Include prepositional phrases indicating location when the phrase is part of a business or
organizational name.
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B. CASES
Include prepositional phrases indicating location to avoid a party name with only one word.
Omit other prepositional phrases indicating location. Omit geographical information after a
comma in a case name.
R11.5.12 “The”
Delete “the” as the first word of a party’s name. Make an exception if the party is “The Queen”
or the “The King,” or when referring to the established popular name in a citation or citation
clause. Also retain “the” if it is part of the name of the object of an in rem action.
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R11.5.14 Unions
Generally, follow the case name as reported. Widely known acronyms are allowed. But
generally, omit additional information after the first full union designation.
For cases with multiple dispositions, include an italicized identifier if useful. In subsequent
references to or citations of that case, the identifier can replace the full case name.
Examples:
Liriano v. Hobart Corp. (Liriano III), 170 F.3d 264, 266 (2d Cir. 1999) (citing Liriano
II, 92 N.Y.2d at 236–37).
R11.5.16 Mandamus
If a mandamus action is known by the name of the judge against whom the writ is sought, that
name can be indicated in an italicized parenthetical.
Example:
If a case is known both by the reported name and a distinct short form name, always include
the reported name in a full citation. The short name may be included in italics in a
parenthetical.
Example:
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B. CASES
INDIGO INKLING
There are multiple ways to incorporate a case citation in the text of an article, brief, or other
written work. In the example below, the case name is stated in the text and the rest of the
citation is included as a separate sentence.
In McDonnell Douglas Corp. v. Green, the Supreme Court held that in a disparate
treatment case, the plaintiff bears the initial burden of establishing a prima facie case of
employment discrimination. 411 U.S. 792 (1973).
In McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973), the Supreme Court held that in
a disparate treatment case, the plaintiff bears the initial burden of establishing a prima facie
case of employment discrimination.
There is no strict rule here, so choose whichever method will be clearer to the reader.
Example:
This table provides an overview of federal and state citations, with the citation given at left and
the full corresponding volume, reporter, and page number at right. Imagine books on the shelf
with the name of the reporter and volume number shown on the book’s spine. Open that
volume to the page given, to find the beginning of the case.
Citation Reporter
Demosthenes v. Baal, 495 U.S. 731 (1990). Vol. 495, p. 731 of United States Reports
United States v. $124,570 U.S. Currency, 873 F.2d Vol. 873, p. 1240 of Federal Reporter,
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Citation Reporter
Gucci America, Inc. v. Guess?, Inc., 831 F. Supp. 2d Vol. 831, p. 723 of Federal Supplement,
723 (S.D.N.Y. 2011). Second Series
Hamburger v. Fry, 338 P.2d 1088 (Okla. 1958). Vol. 338, p. 1088 of Pacific Reporter,
Second Series
Federal and state jurisdictions are listed in Table T1 (federal cases) and Table T3 (state cases),
including the reporters where their cases are published. Here is a key overview of the reporters
containing federal and state cases.
United States Supreme Court cases are printed in the official United States Reports, cited as
<vol.> U.S. <page>. The publication of the United States Reports is significantly delayed from
opinions’ decision date. When there is no U.S. citation available, use the Supreme Court
Reports (abbreviated S. Ct.).
Cases decided by the United States Circuit Courts are printed in the Federal Reporter, Fourth
Series (F.4th) starting with cases in July 2021, then F.3d, F.2d, and F. for older cases.
Federal district court cases are printed in the Federal Supplement, Second Series (F. Supp. 2d),
and F. Supp. for older cases.
Federal cases not selected for publication may be available in the Federal Appendix or other
unofficial reporters.
For state cases, choose the reporter listed in Table T3 for state cases whenever available. The
standard national citation practice is to cite to the West National Reporter System although
many states have a state-specific official reporter or official public-domain citation system (not
reliant on a private publisher’s system). Local customs and court rules vary from the standard
national citation practice, as represented in Table T3.
INDIGO INKLING
For citations to state cases, the case reporter prioritized by Rule R11.3 and Table T3 may not
always be available to researchers using open-access legal information. For example, an
internet site providing free access to cases may provide citation information for the official
44
B. CASES
state reporter in that state, rather than the West National Reporter prioritized in the table.
If you are attempting to conduct case research using free open-access sources, do your best
to adhere to utilize the preferred reporter in Table T3. It may be necessary to use a reliable
second choice, such as the official state reporter or the state’s official medium-neutral
citation format. Try to find cases as published in a reporter with a stable citation, rather
than the original slip copy published by the court the day it decided the case.
When submitting documents to state courts, follow the local rules for citations, selectively
indicated in Table T3. State courts’ local rules often require a parallel citation: i.e., a citation to
both the official state reporter, followed by the unofficial regional and/or state-specific
reporter. Each reporter will have different page numbers, so provide a pincite for each. Also,
when the official reporter title makes the state or court name apparent, don’t include it again in
parentheses.
Harden v. Playboy Enterprises, Inc., 261 Ill. App. 3d 443, 633 N.E.2d 764 (1993).
Harden v. Playboy Enterprises, Inc., 261 Ill. App. 3d 443, 444, 633 N.E.2d 764, 765 (1993).
R11.7 Pincites
Each case citation, whether full or short, should include a pincite to direct the reader to the
specific page being cited.
In a full citation to a case, include a pincite after the first page where the case is found in the
reporter. If the pincite is the first page of the opinion, be sure to still include it by just repeating
the number. Pincites are required in both full and short citations when those citations support
a reference to a specific page of the case. See Rule R15 on short citations for cases and Rule R6
on full and short citations generally.
Pincites can be used to identify the page source for content of an explanatory parenthetical.
Pincites can also be used to identify the page source for content in the textual sentence
supported by the citations sentence or clause that follows.
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Examples:
Mattel, Inc. v. MCA Records, Inc., 296 F.3d 894, 908 (9th Cir. 2002) (“The parties are
advised to chill.”).
Judicial attempts at humor are not new. As the Georgia Court of Appeals quipped in
the mid-1970s, “The D.A. was ready. His case was red-hot. Defendant was present, His
witness was not.” Brown v. State, 216 S.E.2d 356, 356 (Ga. Ct. App. 1975) (reversing
conviction).
Judicial humor is not new, e.g., Brown v. State, 216 S.E.2d 356, 356 (Ga. Ct. App.
1975); and neither is academic critique of it as generally “a dreadful thing,” William
Prosser, The Judicial Humorist vii (1952).
Example:
Gordon v. Secretary of State of New Jersey, 460 F. Supp. 1026, 1026, 1028 (D.N.J.
1978) (dismissing a complaint charging that plaintiff, by reason of his illegal
incarceration in jail, had been deprived of the office of the President of the United
States).
Example:
Helton v. State, 311 So. 2d 381, 382-84 (Fla. Dist. Ct. App. 1975) (reciting the
prosecutor’s closing arguments in a parody of “’Twas the Night Before Christmas”).
Use a paragraph symbol and the paragraph number to pincite to a case published in medium-
neutral format. To refer to a span of paragraphs in the case, use two paragraphs symbols and
numbers indicating the cited span, separated by a hyphen or en dash.
Examples:
46
B. CASES
Id. ¶ 18.
To cite a footnote, provide a page number followed immediately with a footnote number, using
“n.” to show footnote number. There is no space between “n.” and the footnote number.
Example:
Cunningham v. State, 822 S.E.2d 281, 285 n.4 (Ga. 2018) (Hunstein, J.) (“And that’s
all she wrote.”)
Examples:
Learning Curve Toys, Inc. v. PlayWood Toys, Inc., 342 F.3d 714 (7th Cir. 2003).
Mattel, Inc. v. MGA Ent. Inc., 782 F. Supp. 2d 911 (C.D. Cal. 2011).
Barking Hound Village, LLC v. Monyak, 787 S.E.2d 191 (Ga. 2016).
Alexander v. Gen. Acc. Fire & Life Assurance Corp., 98 So. 2d 730 (La. Ct. App. 1957).
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United Use U.S. if the opinion is published in the United States Two Pesos, Inc. v. Taco
States Reports. Cabana, Inc., 505 U.S.
Supreme 763 (1992).
If not, use S. Ct.
Court
Google LLC v. Oracle
Refer to Table T1 for additional options if U.S. and S. Ct. do
Am., Inc., 141 S. Ct. 1183
not apply.
(2021).
United Either F., F.2d, F.3d, or F.4th depending on the decision. Batman v.
States Commissioner, 189 F.2d
Courts 107 (5th Cir. 1951).
of
Nance v. United States,
Appeals
299 F.2d 122, 124 (D.C.
Cir. 1962) (“How do you
know it was me, when I
had a handkerchief over
my face?”).
State Cite to the regional reporter for the region in which the court Terrible v. Terrible, 534
High sits, if the opinion appears there. If not, cite to the state’s P.2d 919 (Nev. 1975).
Courts official reporter, as listed in Table T3. The state’s preferred
State v. One 1970
official reporter may be a public domain (i.e., medium
2-Door Sedan Rambler,
neutral) citation.
136 N.W. 59 (Neb.
See Table T3. 1974).
Other Cite to the regional reporter for the region in which the court Brown v. Swindell, 198
State sits, if the opinion appears there. If not, cite to the state’s So. 2d 432, 434 (La. Ct.
Courts official reporter in Table T3. The state’s preferred official App. 1967).
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Correct Example:
Hamel v. Emp. Sec. Dep't, 966 P.2d 1282 (Wash. Ct. App. 1998).
Incorrect Example:
Hamel v. Emp. Sec. Dep't, 966 P.2d 1282 (Wash. Ct. App., Div. 2 1998).
Where intermediate appellate departments or divisions are relevant to the point being made in
the text, or where local the court rules require citations to include this information. See Table
T3 for more information on state jurisdictions such as Florida and Texas where this
information is required and where the format for such citations varies in local practice. For
standard legal documents seeking a uniform national approach, add the department or division
information to be clear and, if possible, consistent with the general uniform standard for
citations to intermediate appellate courts.
Correct Example:
Before the Florida Supreme Court addressed the question in 2018, Florida District Courts of
Appeals were split on whether judges must disqualify themselves from deciding a case when
they are social-media connections with one or more attorneys in that case. Compare L. Offs. of
Herssein & Herssein, P.A. v. USAA, 229 So. 3d 408 (Fla. 3d Dist. Ct. App. 2017), approved by
271 So. 3d 889 (Fla. 2018), with Domville v. State, 103 So. 3d 184 (Fla. 4th Dist. Ct. App.
2012), disapproved by L. Offs. of Herssein & Herssein, P.A. v. USAA, 271 So. 3d 889 (Fla.
2018).
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INDIGO INKLING
Court abbreviations in case citations convey crucial information. For example, a case citing
“N.Y.” refers to the highest court in the state of New York—the New York Court of Appeals.
But “N.Y. Sup. Ct.” is the proper abbreviation for the New York Supreme Court—which
some will be surprised to know is the name of the trial-level court in the state of New York,
not the state high court. Generally see Table T12 for the correct abbreviation for each state;
and specifically see Table T3 and official state-court websites to confirm the name and level
of each court. Finally, refer to Table T9 for general court abbreviations.
If the identity of the court is clearly and unambiguously indicated by the reporter’s name, do
not include the court in the parenthetical information with the year. When writing to a court
and governed by local rules requiring parallel citations, the court’s identity may be indicated by
required parallel citation information.
Examples:
When using a medium-neutral citation format (alone or in a parallel citation), if the year of the
decision is clearly and unambiguously indicated by the citation format, do not duplicate the
year in the parenthetical information.
Examples:
Water & Energy Sys. Tech., Inc. v. Keil,1999 UT 16, 979 P.2d 829.
Failor v. Megadyne Med. Prods., Inc., 2009 UT App. 179, 213 P.3d 899.
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Some opinions are designated “not for publication” by the issuing court, and will never be
assigned an official reporter citation. Pending and unreported cases generally can be found in
one of the following three source below.
Citations to these electronic databases are similar to regular citations, using the database code
from LEXIS or Westlaw as a substitute for the (non-existent) reporter citation. Pending-case
citations have two additional components: (a) add the docket number before the database
code, and (b) include the full calendar date of the decision in the following parenthetical, not
just the year. Pincites are indicated with “at” and a * attached to the page number.
Citations to these electronic databases should be formatted as follows: <Case Name>, <case
docket number>, <database identifier and electronic report number>, at *<star page number>
<(court, full date)>.
Example:
Yates v. United States, No. 13–7451, 2015 U.S. LEXIS 1503, at *40 (Feb. 25, 2015).
Example:
State v. Green, No. 2012AP1475–CR, 2013 WL 5811261, at *7 (Wis. Ct. App. Oct. 30, 2013).
Some cases, particularly ones that are immediately pending, may initially be accessed only
through a court’s website. If so, include the exact docket number or numbers, as well as the
URL.
Example:
Macy’s Inc. v. Martha Stewart Living Omnimedia, Inc., No. 1728, slip op. at 1 (N.Y. App. Div.
Feb. 26, 2015), http://www.nycourts.gov/reporter/3dseries/2015/2015_01728.htm.
INDIGO INKLING
The Law Librarians for Indigenous Inclusive Citation Practices advocates for The
Bluebook—and uniform citation practices generally—to include information on citing
Indigenous sources of law. As they note on their website at
www.lawlibrariansforindigenousinclusivecitationpractices.org, “[t]he 574 tribal
governments in this country produce thousands of statutes, regulations, and case law each
year that collectively bind millions of Americans.”
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For standard legal documents, we would advise generally following the rules shown in The
Indigo Book, in concert with applicable tribal court rules. Tribal code citations may follow
the same basic format shown in Rules R16-R17, for example:
15. N.N.C. § 614(A) (as amended by Navajo Nation Council Resolution No. CO-48-14, Nov.
7, 2014).
A case decided by a tribal judicial authority may be able to be cited consistently with Rule
R11 by name, reporter, and volume—if it is printed in one of the tribal law reporters. Or it
may be cited using the format for slip opinions and cases found exclusively online (R12.4.2).
Navajo Nation v. Hunter, 7 Nav. R. 194, 195 (Nav. Sup. Ct. 1996).
Corp. of the Pres. of the Church of Jesus Christ of Latter-Day Saints v. Window Rock Dist.
Ct., No. SC-CV-42-18, 2018 WL 7149968 (Nav. Sup. Ct. Dec. 28, 2018).
In re Lotus Justice, No. SC-2022-01, slip op. (Cherokee Sup. Ct. Feb. 14, 2022),
https://www.cherokeecourts.org/Portals/cherokeecourts/Documents/Supreme%20Court
/Order%20and%20Opinions/SC-22-01%202-Notice%202-14-22.pdf?ver=2022-02-14
-142814-147
Abbreviations for tribal sources can be found at reference sites for Indigenous and Tribal
Law such as the National Indian Law Library including its Tribal Law Gateway and
Research Guides, http://www.narf.org/nill/triballaw/index.html. A table of tribal nations is
available at the Bureau of Indian Affairs’ Tribal Leaders Directory for federally recognized
tribes, https://www.bia.gov/service/tribal-leaders-directory. Many U.S. and Canadian law
schools also have helpful research guides posted on their law library websites. For academic
legal documents, follow the citation conventions set forth at the relevant publication.
Examples:
United States v. Leggett, 23 F.3d 409 (6th Cir. 1994) (unpublished table decision).
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Ward v. Rock Against Racism, 491 U.S. 781 (1989) (Marshall, J., dissenting).
Dep’t of Revenue v. James B. Beam Distilling Co., 377 U.S. 341, 349 (1964) (7–2 decision)
(Black, J., dissenting).
Examples:
Stambovsky v. Ackley, 572 N.Y.S.2d 672, 674 (App. Div. 1991) (“[A]s a matter of law, the house
is haunted.”).
People v. Foranyic, 74 Cal. Rptr. 2d 804, 807 (Ct. App. 1998) (holding that police have
probable cause to detain someone they see riding a bike at 3 a.m., carrying an axe).
Dep’t of Revenue v. James B. Beam Distilling Co., 377 U.S. 341, 349 (1964) (7–2 decision)
(Black, J., dissenting) (disagreeing with Justice Goldberg as to the relative merits of bourbon
and scotch).
INDIGO INKLING
The United States Supreme Court is famous for hearing oral arguments and issuing judicial
opinions, but it has recently increased the practice of making decisions through the so-
called “shadow docket.” E.g., Stephen I. Vladeck, The Solicitor General and the Shadow
Docket, 133 Harv. L. Rev. 123 (2019); William Baude, Foreword: The Supreme Court’s
Shadow Docket, 9 N.Y.U. J.L. & Liberty 1 (2015). These rulings are issued without full
briefing and argument and, in many cases, without identifying a particular justice as the
author.
To cite Supreme Court dispositions on its shadow docket, follow Indigo Book Rules R11-R12
on cases citations to the extent possible. For example, provide a citation to Supreme Court
Reports until the official United States Reports citation with pagination becomes available.
A parenthetical may be used to indicate the type of ruling, following the title or other
information provided with the ruling:
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Use the above parentheticals only if the disposition explictly indicates it is per curiam or
issued by a particular justice in chambers. Other rulings are not labeled as per curiam or
signed in chambers. The traditional rule for citing such decisions was to add the
parenthetical “(mem.)” after the citation:
The decisions falling into this category are not typically labeled “memorandum” by the
Court itself; rather, this label comes from traditional citation practice to indicate what
would otherwise look the same as a full opinion. Thus, we submit that other more
descriptive parentheticals may be used in addition to or instead of (mem.) to indicate the
posture of the decision:
United States v. Higgs, 141 S. Ct. 645 (2021) (emergency vacatur of stay and reversal,
designating Indiana as state for inmate’s execution under 18 U.S.C. § 3596).
Whole Woman’s Health v. Jackson, 141 S. Ct. 2494 (2021) (mem.) (unsigned, on
application for injunctive relief).
Shadow-docket decisions by the majority of the Court can be, and recently often are,
accompanied by signed concurring or dissenting opinions. Dissents and other statements
attached to the decision may be indicated in a similar fashion to concurrences and dissents
from fully argued opinions on the merits. When one justice concurs or dissents in an
opinion attached to a shadow docket decision and one or more justices join that opinion,
indicate only the authoring justice. Indicate a pincite to concurring or dissenting opinions.
The parenthetical (mem.) or other appropriate notation may optionally be included as well,
to indicate that the concurrence or dissent is referring to an action that does not itself
constitute a full formal opinion.
Ala. Ass’n of Realtors v. Dep’t of Health & Hum. Servs., 141 S. Ct. 2485, 2485 (2021)
(mem.) (Roberts, C.J., concurring).
United States v. Higgs, 141 S. Ct. 645, 647 (2021) (Sotomayor, J., dissenting from vote).
54
B. CASES
INDIGO INKLING
The United States is a common law system, where court decisions play an important role in
defining what the law is. To figure out the difference between good law and bad law, we
have to look at the case’s subsequent history to make sure it was not vacated or reversed on
the point being relied upon in a cited assertion. These types of important subsequent
history are required by the Uniform System of Citation. On the other hand, some
subsequent history is generally unimportant and should be omitted from the citation.
Examples include the denial of a motion for reconsideration, or the denial of a petition for
certiorari in a case decided more than two years ago. See Table T3 for some state-specific
variations, and of course follow local practice and local court rules on subsequent history.
Note that subsequent history is the history of that particular case in litigation. If a different
case (unrelated parties but a similar legal issue) later overrules an older case’s holding, that
case is no longer good law for that point—but subsequent history is not involved in the
citation. This is but one example of how legal citation overlaps with legal analysis itself. If a
writer is citing a case that was later overruled, the writer should not simply polish the
citation’s mandatory subsequent history, but rather re-consider why to cite that “bad law”
in the first place.
Always incorporate the following explanatory phrases when applicable, italicized, and followed
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by a comma and the citation information for the subsequent history. Include other subsequent
history commensurate with this list, to indicate the weight of authority and whether the
primary case being cited is good law for all or any points.
rev’d on other grounds Case has been reversed on a different ground other
than the one for which it is being cited.
Examples:
In re Verizon Internet Servs., Inc., 257 F. Supp. 2d 244 (D.D.C. 2003), rev’d on other grounds,
Recording Indus. Ass’n of Am., Inc. v. Verizon Internet Servs., Inc., 351 F.3d 1229 (D.C. Cir.
2003).
—Note: This subsequent history is always required because the primary case being cited has
been reversed on at least one basis.
B.L. v. Mahanoy Area Sch. Dist., 964 F.3d 170 (3d Cir. 2020), cert. granted, No. 20-255 (Jan.
8, 2021).
—Note: This would be an appropriate citation while the Supreme Court’s decision and opinion
remained pending. After the opinion, it is unlikely that this citation would be needed since the
Supreme Court opinion itself is the final authority.
The district court’s decision withstood all layers of federal-appellate review. Energy & Env't
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B. CASES
Legal Inst. v. Epel, 43 F. Supp. 3d 1171 (D. Colo. 2014), aff’d, 793 F.3d 1169 (10th Cir. 2015),
cert. denied, 577 U.S. 1043 (2015).
—Note: This denial of certiorari is included because it is integral to the sentence’s claim. This
denial of certiorari would be appropriate even after the two-year period for including denial of
petitions for certiorari had expired.
Include indirect history from other subsequent litigations or collateral litigation, when the
indirect history is directly negative or necessary for the point being made. The clearest example
is overruled by <x>.
Examples:
Hemerley v. Am. Fam. Mut. Ins. Co., 379 N.W.2d 860 (Wis. Ct. App. 1985), overruled by Hull
v. St. Farm Mut. Auto. Ins. Co., 586 N.W.2d 863 (Wis. 1998).
Schuster v. Derocili, 775 A.2d 1029 (Del. 2001), superseded by statute, 19 Del. Code Ann. §
712(b) (2005), as recognized in Yatzus v. Appoquinimink Sch. Dist., 458 F. Supp. 2d 235 (D.
Del. 2006).
Example:
Lerman v. Comm’r, 939 F.2d 44 (3d Cir. 1991), rev’d sub nom. Horn v. Comm’r, 968
F.2d 1229 (D.C. Cir. 1992).
Do not provide the new case name if either the parties’ names are merely reversed or if the
subsequent history is simply a denial of certiorari or rehearing:
Correct:
United States v. Schmuck, 840 F.2d 384 (7th Cir. 1988), aff’d, 489 U.S. 705 (1989).
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Incorrect:
United States v. Schmuck, 840 F.2d 384 (7th Cir. 1988), aff’d, Schmuck v. United
States, 489 U.S. 705 (1989).
Example:
INDIGO INKLING
Legal citation is not just a set of formatting rules, but an expression of ethics, an expression
extending far beyond the dictate to literally cite one’s sources. The ethical dimensions of
legal citation encompass its broader impacts such as how these rules socialize new lawyers-
in-training, how they function within the legal world, what they represent about law and its
practitioners, what they omit, and what effects they cast over the law’s sphere of influence.
See, e.g., Susie Salmon, Shedding the Uniform: Beyond a “Uniform System of Citation” to
a More Efficient Fit, 99 Marq. L. Rev. 763 (2016); Jennifer Elisa Chapman, Citation Ethics:
Toward an Ethical Framework of Legal Citation (May 29, 2021), Yale Law Library Citation
and the Law Symposium (forthcoming 2021), available at https://ssrn.com/
abstract=3856202. Citation of cases involving enslaved persons are one example.
Historically, these cases were cited no differently than any other case. As of January 2021,
the latest printing of The Bluebook (21st ed.) added a rule to expand the citation for such
cases, which must now include a parenthetical indicating that an enslaved person or people
were parties or at issue in the case. This Second Edition of The Indigo Book expresses this
rule and welcomes the continued examination of legal citation rules and practices.
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B. CASES
For the case name, use the chosen party’s name—usually the first-named party’s
name—consistent with these rules for selecting a short-form citation and consistent with the
abbreviation rules in Rule R11 for all case names (full citation or short citation). For the
citation format, include the volume of the reporter, the reporter, the word “at” and the pincite
to the page being cited.
Within the text sentence or (preferably) after the text sentence, provide a truncated citation
sentence in the form of <volume> <Name of Reporter> at <pincite>.
Examples:
The court in Fenton also held the lower court erred in awarding damages based on loss of fair
market value of property due to the flying balls. 233 N.E.2d at 219.
As the court further noted in Fenton, 233 N.E.2d at 219, the lower court erred in awarding
damages based on loss of fair market value of property due to the flying balls.
Once a case has been cited in full, you may refer to the case by a short-citation form.
Specifically, you provide a short-form citation sentence or clause with truncated information
compared to the full citation. The reference must be unambiguous, and the full citation must
be easily accessible earlier in the text.
Discretion may be applied to repeat the full-citation form later in a document when useful to
the reader, such as after five short-form uses of id., five footnotes using id., or after a new
heading or page break.
In general, the short citation uses the first-named party in the case name. As with full citations,
the case name is italicized but the comma after the case name is not italicized. The shortened
citation form omits the “v.” (for versus) and second-named party after the “v.” The shortened
citation form also omits the first page of the case as found in the reporter, and simply provides
an “at” with the pincite.
For cases, a short form citation usually includes: <The First Party of the Case Name>, <volume
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number> <Reporter> at <pincite>. As shown in Rule R15.1, if the shortened case name is
incorporated into the textual sentence, do not repeat that shortened name in the short-form
citation after the textual sentence.
Do not use the first party of the case name if that party either is a geographical or governmental
unit or a party name that is used for multiple cases. Choose the second party name if needed to
avoid confusion.
Examples:
United States v. Carmel, 548 F.3d 571 (7th Cir. 2008) becomes Carmel, 548 F.3d at 573.
Shorten a long party name, but only if the shortening saves significant useful space and if the
reference remains clear. Use a [hereinafter <x>] designation if needed.
Examples:
Home Depot USA, Inc. v. Jackson, 139 S. Ct. 1743, 1744 (2019) becomes Home Depot, 139 S.
Ct. at 1744.
A Book Named “John Cleland’s Memoirs of a Woman of Pleasure” v. Attorney Gen. of Mass.,
383 U.S. 413, 418 (1966) [hereinafter, Memoirs] can then become Memoirs, 383 U.S. at 418.
R15.3 Id.
R15.3.1 Id. with immediately preceding citation (same page of case)
If you are citing to the same case referenced in the immediately preceding citation, use id. as
the short form citation. Id. by itself refers to the same case and same pincite in that case.
Example:
When the author of a work is a judge or legislator, it carries the force of law and cannot be
copyrighted. Georgia v. Public.Resource.org, 140 S. Ct. 1498, 1513 (2020). To hold otherwise
would be to discourage the use of “official legal works that illuminate the law we are all
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B. CASES
If you are referring to the immediately preceding case, but to a different page, use id. at
<pincite>.
Example:
Fair use is ultimately a legal question because the question “primarily involves legal work.”
Google LLC v. Oracle Am., Inc., 141 S. Ct. 1183, 1199 (2021). Although “subsidiary factual
questions” may be involved, the ultimate question is legal rather than factual. Id. at 1200.
Id. should be used only if the preceding citation cites to one source.
Correct:
Incorrect:
Correct:
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INDIGO INKLING
The short form id.—capitalized as Id. when it starts a citation sentence—can be used only to
refer to the immediately preceding citation. The standard for what is immediately preceding
is strict. Do not use id. simply because a full citation has been given somewhere at some
point previously in the text; it is not catchall short citation but must be tailored to context.
Id. can be used after a citation to a single source (a full or a short citation, the important
characteristic being a citation to one and only one source). Id. cannot follow a string
citation listing two or more sources. It also cannot be used after any intervening textual
reference, such as mentioning a different case or other authority by name. Citing multiple
sources in a string or mentioning other intervening sources creates possible ambiguity and
thus makes id. unhelpful and incorrect.
There is one exception to this strict construction of when to use id. If the preceding citation
includes a parenthetical citing a case within that parenthetical, that citation-within-a-
citation does not foreclose the use of id. In that scenario, id. may be used to cite back to the
immediately preceding citation to which the citation-within-a-citation is attached. Thus, a
source cited parenthetically does not become the immediately preceding citation. This is
structurally different from a string citation. Do not use id. after a string citation, even to
attempt to refer to the final citation in the string.
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C. STATUTES, RULES, REGULATIONS, AND OTHER LEGISLATIVE & ADMINISTRATIVE
MATERIALS
INDIGO INKLING
Federal statutes, like most state statutes, use the § symbol to indicate the specific codified
section. Traditionally, the section symbol is always followed by a space—for example, § 107
or §§ 106-107 for a span of sections.
Even though the Uniform System of Citation dictates a space between § and the section
number, sometimes in practice that space is intentionally and systematically omitted. The
United States Supreme Court itself does not use the space, and some SCOTUS briefs do
while others do not (per an unscientific review of 2021 opinions and briefs). The decision
may be strategic in briefs subject to a word-count rule such as the 13,000-word maximum
imposed by Federal Rule of Appellate Procedure 32. The Bluebook, however, does not on its
face permit this deviation.
The Bluebook has very recently, however, acknowledged the role of word counts in another
context: whether to keep the space between F. and Supp. in F. Supp. or between S. and Ct.
in S. Ct. This space is technically required by the Uniform System of Citation’s rule that
adjacent capitals like S.E. may be closed up, but a capital may not close up with an
abbreviation that is not a single capital, like Ct. in S. Ct. As of 2020, The
Bluebook’sBluepages Rule B6 softened its stance, advising writers they may close up other
traditionally expected spaces in S. Ct. and F. Supp. 2d so as to conserve space. In a
potentially controversial (?) stance, we submit that closing up the space between the section
symbol and section number may be an equivalent acceptable deviation from traditional
citation mechanics, for writers facing word-count pressure. The Supreme Court and
members of the Supreme Court Bar do it even when holding a client’s case in their hands.
So maybe you can too.
For citations to the current United States Code (the official code of the United States and thus
the preferred citation), cite the title, the United States Code, the section symbol or symbols,
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and section number or numbers being cited. The name of the Act being cited may be included
before the citation, if appropriate.
Examples:
17 U.S.C. § 107.
18 U.S.C. § 1030.
R16.1.2 Year optional for current sections of the United States Code
The year in a United States Code citation is optional if the citation refers to the current codified
statute. Omitting the year from a U.S.C. citation indicates the most current version of the
federal statute being cited, whether that current version is published in the codified edition or a
more recent supplement issued to amend the codified edition.
The U.S.C. is codified once every six years, with various supplements issued in the interim six
years between codification. For historical citations to previous versions of the United States
Code, citations should be to the appropriate codifying year (e.g., 2000, 2006, 2012). Cite the
most recent edition that includes the version of the statute being cited. If you are citing to a
historical version of a statute first published in a supplement published in the interim period
between official codifications, be sure to consult the supplements, indicate the supplement’s
title and year of publication in the citation.
Example:
If the U.S.C. cite is not available, then cite to an unofficial code such as U.S. Code Annotated or
U.S. Code Service. The citation form is
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C. STATUTES, RULES, REGULATIONS, AND OTHER LEGISLATIVE & ADMINISTRATIVE
MATERIALS
As with the United States Code, the year is not required in citations to the current code.
Examples:
For citations where the date is relevant or for historical code citations, indicate the date
parenthetically. The date consist of the year through which the code section is current, or may
include “current through” an exact date or legislative session, if relevant.
Examples:
The original section numbering of enacted legislation does not inherently correspond to the
section numbering in codified statutes. When naming and citing an Act in its original enacted
form and in its codified form, include parallel citations to original section number in the Act,
and the codified location.
Use the following form: <Name of Statute> <original section number>, <title> <Abbreviation
for Name of Statutory Code> § <section number> <(<Name of Publisher, but only if citing
unofficial code> <year published>)>.
Examples:
Drug Price Competition and Patent Term Restoration Act § 202, 17 U.S.C. § 271(e).
If neither a United States Code or unofficial annotated code citation is available, then cite to
the Public Law Number and parallel official session laws (i.e., the Statutes at Large). Omit the
year of passage if it is part of the Act’s name. For a citation without a pincite, use the following
format: <Name of Statute,> Pub. L. No. <____>, <volume> Stat. <page number> <(year
passed)>.
The citation may include pincite to the specific section in the original Act and the page in the
session laws. For a citation with a pincite, use the following format: <Name of Statute,> Pub. L.
No. <____>, <original section number>, <volume> Stat. <page number>, <page pinpoint>
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<(year passed)>.
Examples:
Patient Protection and Affordable Care Act, Pub. L. No. 111-148, § 1101, 124 Stat. 119, 141-43
(2010).
Family Sponsor Immigration Act of 2002, Pub. L. No. 107-150, 116 Stat. 74.
Examples:
§ 107.
Id.
Id. § 106.
INDIGO INKLING
“Session laws” are a bound collection of all statutes enacted by a given legislature, each
volume collecting statutes chronologically in the year they were passed. The Statutes at
Large (“Stat.”) is the official compilation for federal session laws. Generally, only cite to
session laws if the official or unofficial code is unavailable or insufficient, or if you need to
refer to the historical fact of the statute’s enactment.
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C. STATUTES, RULES, REGULATIONS, AND OTHER LEGISLATIVE & ADMINISTRATIVE
MATERIALS
A citation to a state code must include the code’s name (abbreviated) and identifying
information such as the code volume and section number being cited. State-code formats vary
by state. See Table T3. The citation must also include a parenthetical providing the publisher’s
name if necessary for an unofficial citation, as shown in Table T3; and the current year of that
code. State code citations are never underlined (even if they appear underlined in online
hyperlinked sources.)
Examples:
Some state codes use subject-matter abbreviations in their citation formats. Follow Table T3
and the abbreviations shown there to cite such codes.
Examples:
Example:
Tex. Civ. Prac. & Rem. Code Ann. § 27.001 (West 2021).
INDIGO INKLING
The Uniform System of Citation requires full citations of state statutes to include the code’s
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publication date, unlike citations to the United States Code. But in many state jurisdictions,
common practice suggests—or local court rules require—omitting the publication year of
the state code. Consult Table T3 and state-specific rules and resources.
Example:
Examples:
§ 27.001.
Id.
Id. § 209.
Cite current federal or state rules by indicating the abbreviation of the source, followed by the
rule number. Do not use a section symbol (§) when citing rules of evidence or procedure,
unless using a jurisdiction-specific citation form that requires it. Do not include a date for
current rules of evidence or procedure. Include the date of repeal if citing a historical rule no
longer in force, and other appropriate information in a parenthetical.
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C. STATUTES, RULES, REGULATIONS, AND OTHER LEGISLATIVE & ADMINISTRATIVE
MATERIALS
Examples:
Fed. R. App. P. 1.
Cite uniform rules in the same manner as for state or federal rules. Follow how the rules
indicate they should be cited as well as how they are in fact cited.
R18.1.3 Abbreviations
In citation sentences and clauses, follow customary abbreviations for the rules being cited. As
with all state citations, local customs and rules may differ.
Examples:
N.J.R.E. (local)
Rule (local)
Follow the title and edition with the number of the section being cited and, parenthetically, the
publisher and the year that edition was published. Use the following form: Restatement
(<spelled ordinal>) of <Subject Matter> <: Subject-Matter Subtitle (if applicable)> § <section
number> (<publisher> <year published>).
A comment may be indicated by its letter designation after the Restatement section. Comments
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The Indigo Book
Examples:
Restatement (Third) of the Law Governing Lawyers § 2 cmt. e (Am. L. Inst. 2000).
Do not abbreviate or use numerical form for the ordinal portion of the Restatement title such
as “(Second)”. You may optionally abbreviate words in the Restatement title as noted in Table
T11, such as “Property” as “Prop.” Try to avoid awkward and non-traditional abbreviations
such as “Restatement (Third) of Conflict of Ls.” and “Restatement (Second) of Conts.” Use the
option to abbreviate words of eight letters or more such as “Enrichment” as “Enrich.” if
desired, avoiding ambiguity with established abbreviations.
INDIGO INKLING
The recent history of Restatement citations is a good case study in how citation formats
evolve and are influenced by user feedback and advocacy. As of the 19th edition of The
Bluebook, published in 2010, Restatement citations followed a fairly slim format:
The 20th edition of The Bluebook, published in 2015, added the requirement of
parenthetically indicating the institutional author along with the year in citations to
Restatements, Uniform Acts, and Model Rules:
See Richard L. Revesz, The American Law Institute and the Bluebook, The ALI Reporter
(Fall 2015), at 3, https://www.ali.org/news/articles/ali-reporter-fall-2015/ (noting that this
new citation format was added to The Bluebook at the request of the American Law
Institute to protect the American Law Institute’s brand and the influence of its work). The
21st edition of The Bluebook, published in 2020, stated a slightly modifed citation:
As of 2020, this relatively recent citation development may be appropriate in scholarly legal
writing and is used by law reviews closely implementing the latest version of The Bluebook
specifically. This suggested citation format has been picked up by some courts but does not
appear to have been systematically adopted as of 2022. See, e.g., Gallardo by & through
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C. STATUTES, RULES, REGULATIONS, AND OTHER LEGISLATIVE & ADMINISTRATIVE
MATERIALS
Vassallo v. Marstiller, 142 S. Ct. 1571, 1761 (2022) (citing Restatement (Second) of
Contracts § 321(1) (1981)).
Examples:
U.C.C. § 9-105.
Examples:
Unif. Trade Secrets Act § 1(4) (Unif. L. Comm’n 1985) (as amended).
Citations to federal administrative rules and regulations take the following form for citing a
section. Provide as specific and precise a citation as the source allows.
Examples:
Citations to a part (that is a particular, defined “Part”) of the C.F.R. take the following form.:
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<title number of C.F.R. provision> C.F.R. pt. <part number> <(year published)>.
If the regulation is generally referred to by name or listing the name and/or the name of the
agency issuing the regulation would otherwise improve clarity, include it at the beginning of
the citation. Citations to administrative rules and regulations that include the regulation name
take the following form:
<Name of the Regulation and/or Name of the Agency Promulgating the Regulation>, <title no.
of C.F.R. provision> C.F.R. § <section number> <(year published)>.
Examples:
DOE Employee Standards of Conduct with Regard to Privacy, 10 C.F.R. § 1008.3 (2020).
FDA Standards of Identity for Food, 21 C.F.R. Parts 130 to 169 (2020).
Examples:
Missouri Code of State Regulations Title 15, Mo. Code Regs. Ann. tit. 15, § 15 CSR
Section 30-200.030, updated as of 2020 30-200.030 (2020). 30-200.030.
New Jersey Administrative Code Section 2:16-1.1, N.J. Admin. Code § 2:16-1.1 N.J.A.C.
updated as of 2020 (2020). 2:16-1.1.
Agency adjudications are similar to case citations but more streamlined. Use only the first-
listed private party. Omit all procedural words such as “In re” and similar. See Table T2 of The
Indigo Book for specific guidance on citing agency adjudications and arbitration citations.
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C. STATUTES, RULES, REGULATIONS, AND OTHER LEGISLATIVE & ADMINISTRATIVE
MATERIALS
Example:
R19.3.2 Arbitrations
Agency arbitrations follow the format for case citations (Rule R11) if they have adversary
parties and the citation for an agency adjudication (Rule R19.3.1) if they do not. Indicate the
arbitrator’s name and abbreviated title Arb. at the end of the citation.
Examples:
Landrys Inc., 199 L.R.R.M. (BL) ¶ 2103 (N.L.R.B. Div. of Judges June 26, 2014).
Online Political Files of Trending Media, Inc., File No.: POL-070121-27365113 (FCC Feb. 12,
2021) (order and attached consent decree), https://docs.fcc.gov/public/attachments/DA-21
-156A1.pdf.
Ronnie v. Office Depot, Inc., Arb. Case No. 2019-0020, ALJ Case No. 2018-SOX-00006 (Dep’t
of Labor Sept. 29, 2020), https://www.dol.gov/sites/dolgov/files/OALJ/PUBLIC/ARB
/DECISIONS/ARB_DECISIONS/SOX/19_020_SOXP.PDF.
Amazon, Inc. and Amazon Logistics, Inc., File No. 1923123, 2021 WL 489846 (FTC Feb. 2,
2021) (agreement containing consent order), https://www.ftc.gov/system/files/documents
/cases/amazon_flex_order_with_no_signatures.pdf.
R19.3.4 Pincites
Pincite to specific pages in the document by using page numbers, paragraph numbers, star
pagination to proprietary page numbers, or another appropriate pincite reference. See Rule R5.
<Title of Proposed Rule> , <Volume> Fed. Reg. <Page> , <(proposed on <date rule was
proposed>)> (to be codified at <intended C.F.R. citation>)>, <URL where Proposed Rule can
be found>.
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If the proposed rule is not yet included in the Federal Register, provide a citation to the
agency’s website including docket number if available and URL.
Include the commenter’s name and the proposed rule that is the subject of comment, followed
by the exact date and URL:
Include the docket number or comment number in the citation, if applicable and helpful.
Examples:
Georgia Dep’t of Agric., Public Submission on the FDA’s Comprehensive, Multi-Year Nutrition
Innovation Strategy (Aug. 23, 2018), https://www.regulations.gov/comment/FDA-2018-N
-2381-0690.
Georgia Dep’t of Agric., Public Submission on the FDA’s Comprehensive, Multi-Year Nutrition
Innovation Strategy (83 Fed. Reg. 30180 (June 27, 2018)) (comment submitted Aug. 23, 2018),
https://www.regulations.gov/comment/FDA-2018-N-2381-0690.
When citing a comment in which administrative procedure requires an agency response and
when the agency has in fact issued its response, supplement or replace the URL of the
comment standing alone to add citation information for the rule appendix or other source
containing both the comment and the agency response.
INDIGO INKLING
Citations to agency sources must build on the fundamentals of legal citation, while adapting
the special conventions of administrative-law practice and the relevant agency or agencies.
Fundamentally, all legal citations should provide the correct information including title,
issuing agency, date, and indexing information such that the source can be found and the
reader can assess the source in context. Special conventions of administrative-law practice
vary by federal and state agency. Specialty conventions may include omitting information
(such as a date where it is superfluous), citing to agency-specific sources rather than general
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C. STATUTES, RULES, REGULATIONS, AND OTHER LEGISLATIVE & ADMINISTRATIVE
MATERIALS
federal sources, or citing general federal sources plus additional parallel citations, cross-
references, and/or URLs. Those who work frequently with a particular agency will often
rely more heavily on the agency’s website or other sources than on general publication in
the Federal Register.
Rates for Interstate Inmate Calling Services, 85 Fed. Reg. 67,450 (Oct. 23, 2020) (to be
codified at 47 C.F.R. pt. 64); Rates for Interstate Inmate Calling Services, 85 Fed. Reg.
67,480 (proposed Oct. 23, 2020) (to be codified at 47 C.F.R. pt. 64).
But an attorney or policy advocate knowledgeable about FCC customs might cite the source
more like the following, knowing that the Federal Register documents are only a summary
of the FCC's full document, released more than two months after the FCC's initial release of
the document, and missing the separate statements of FCC commissioners on the
document:
Rates for Interstate Inmate Calling Services, Report and Order on Remand and Fourth
Further Notice of Proposed Rulemaking, WC Docket No. 12-375, 35 FCC Rcd. 8485 (Aug. 7,
2020), https://www.fcc.gov/document/fcc-seeks-reduce-rates-and-charges-inmate-calling-
services-0.
Table T1 provides more detailed information about federal-agency practice, and Table T3
provides information on state-specific administrative-law citations (acknowledging that
comprehensive treatment of state practice is beyond the scope of The Indigo Book). For
work focused on particular agencies, any overall source expressing the Uniform System of
Citation should be supplemented by obtaining agency-specific citation guides, studying
recent samples of work in that agency, and working with experienced practitioners. For
these examples, we are grateful to Blake Reid, Clinical Professor and Director of the
Samuelson-Glushko Technology Law & Policy Clinic at the University of Colorado School of
Law.
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Code.
R20.1.1 I.R.C.
Citations to the code itself take the following form: I.R.C. § <section number> .
Citations to Title 26 of the United States Code, which is where the Internal Revenue Code is
codified, take the following form: 26 U.S.C. § <section number>.
Examples:
I.R.C. § 312.
26 U.S.C. § 312.
Indicate the publisher if citing to an unofficial code. Do not indicate the year when citing the
current unofficial code, but do include the year if citing a past edition or dated supplement.
Examples:
Examples:
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C. STATUTES, RULES, REGULATIONS, AND OTHER LEGISLATIVE & ADMINISTRATIVE
MATERIALS
Example:
Type Abbreviation
Senate Bill S.
Examples:
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Clinical Social Work Medicare Equality Act of 2001, S. 1083, 107th Cong. § 2(b) (2001).
ABLE Act of 2014, H.R. 647, 113th Cong. (as passed by House, Dec. 3, 2014).
H.R. 1746, 111th Cong. § 2(c)(4) (as reported by H. Comm. on Transp. and Infrastructure, Apr.
23, 2009).
INDIGO INKLING
Every two years, a new Congress is constituted, based on the two-year term for Members of
Congress set forth in Article 1, Section 2 of the United States Constitution. Each of these
Congresses has its own number, and that number is crucial in legislative-history citations.
The 2021-22 Congress (elected in 2020) is the 117th Congress. Public Laws enacted by this
Congress and signed by the President will follow a citation format such as Pub. L. 117-1 (the
first act to be enacted sequentially by the 117th Congress). The 2019-2020 Congress (elected
in 2018) was the 116th Congress. Those Public Laws would follow a citation format such as
Pub. L. 116-25 (the twenty-fifth act to be passed by the 116th Congress); and so on. Likewise
other legislative documents use the number of that Congress as a core piece of the citation.
Online resources for government-document research seem to be constantly in flux; consult
Congress.gov or Govinfo.gov for more information.
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C. STATUTES, RULES, REGULATIONS, AND OTHER LEGISLATIVE & ADMINISTRATIVE
MATERIALS
Example:
Cite committee hearings as follows: <full title of hearing>: Hearing on <bill number, if any>
Before the <name of committee or subcommittee>, <number of the Congress> <optional
pincite to page number> <year of publication> <name and title of speaker>. For the names of
subcommittees and committees, abbreviate according to the form set out in Table T5, Table
T11, and Table T12. For the names of individuals, use Table T10.
For state committee hearings, cite as follows: <full title of hearing>: Hearing on <bill number,
if any> Before the <name of committee or subcommittee>, <number of the legislative session>
<optional pincite to page number> <abbreviation for the state’s name from Table T12> <year
of publication> <name and title of speaker>. Use the same abbreviation resources as for
Congressional committee hearings.
Examples:
Cell Tax Fairness Act of 2008: Hearing on H.R. 5793 Before the Subcomm. on
Commercial and Administrative Law of the H. Comm. on the Judiciary, 110th Cong.
12 (2008) (statement of Zoe Lofgren, Member, H. Comm. on the Judiciary).
Welfare and Poverty in America: Hearing before the S. Comm. on Fin., 114th Cong.
(2015) (statement of Dr. Pamela Loprest, Senior Fellow, Urban Institute).
Testimony from invited guests addressing the use of eminent domain in the State:
Hearing before the Assemb. Commerce and Econ. Dev. Com., 2006–2007 Sess. 5
(N.J. 2006) (statement of Guy R. Gregg, Assemblyman).
Hearing on L.D. 319 Before the Health and Human Servs. Comm., 127th Leg., Reg.
Sess. (Me. 2015) (statement of Susan Lamb, Executive Director, Maine Chapter of the
National Association of Social Workers).
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Cite numbered federal reports as follows: <name of house, in small caps> Rep. No. <number of
the Congress, followed by a hyphen and the number of the report>, <at optional pincite> <year
of publication> <parenthetical to indicate conference report, if applicable>.
Examples:
Citations to federal and state non-statutory legislative materials, including legislative history
and unenacted bills, aren’t expressed in a uniform manner, but generally include the following
elements:
• title, if available,
• name of legislative body, abbreviated
• section number, page no. or number of report
• number of Congress and/or legislative session
• (publication year)
• (if the bill or resolution was enacted). Only include this additional parenthetical if the
bill was enacted; if unenacted, you don’t need to add anything extra.
Examples:
American Clean Energy and Security Act, H.R. 2454, 111th Cong. (2009).
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C. STATUTES, RULES, REGULATIONS, AND OTHER LEGISLATIVE & ADMINISTRATIVE
MATERIALS
R22.2 Id.
Id. may be used to identify the immediately preceding source consistent with Rule R6. Id. can
be used for different subsections of the same code title and section, or for different code
sections within the same title. A subsequent citation to a different title of that code necessitates
a more complete short-form citation than Id.
For current Constitutional provisions, do not include a date. Parenthetical information may be
added consistent with Rule R10, such as for repeal or amendment.
The format is as follows: <U.S. Const.> <cited section of constitution, abbreviated> <number
of article or amendment in Roman numeral form> <§ and pinpoint, if applicable> <(additional
information, if needed)>.
Examples:
Examples:
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D. COURT & LITIGATION DOCUMENTS
INDIGO INKLING
Citing orders to a court during active litigation in that court will vary and depend on that
court’s own rules and customs. In contexts outside the litigation, orders should be cited
consistently with the opinion rules in Rule R12.4.1 Thus, an order in a 2022 labor dispute
involving a Memphis Starbucks would be cited differently when participating in the
litigation and outside of it.
McKinney v. Starbucks Corp., No. 2:22-cv-02292, Order Denying in Part and Granting in
Part Motion of Workers United to Intervene or, in the Alternative, to Participate as
Amicus Curiae, at 2, n. 1 (W.D. Tenn. May 10, 2022).
ECF and Page ID page citations vary court by court, and full coverage of the Case
Management/Electronic Case Files system and PACER is beyond the scope of The Indigo
Book. We note our support for open-access initiatives such as RECAP, which is a searchable
online archive, browser extension, and email alert capturing utility made available by the
Free Law Project and Center for Information Technology Policy at Princeton.
In federal court, court and litigation documents must be filed with the federal government’s
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Case Management/Electronic Case Files system, variously known as CM/ECF (for case
management and electronic case filing, respectively) and PACER (for accessing case materials).
Thus, federal court documents have traditional document names, pagination, and in some
types of pleading documents, paragraph designations provided by the filer; as well as an
assigned ECF number for the document and PageID numbering within the document provided
by the CM/ECF system.
Examples:
Def. Acme’s Resp. to Pl. Morrison’s Req. for Admis. No. 2.A.
R. at 22.
J.A. at 137.
Generally cite the appellate record with an “at.” Record citations also sometimes omit the “at”
to save on a word count. Most importantly, be accurate and be internally consistent.
Examples:
R. at 2.
R. 2.
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D. COURT & LITIGATION DOCUMENTS
Example:
R24.2.3 Commas
Use commas if necessary to avoid confusion. When abbreviating both a document name and an
exhibit to that document, add a comma after the Exhibit reference before the pincite.
Example:
Examples:
Examples:
(Petition for Temporary Injunction Pursuant to Section 10(j) of the National Labor Relations
Act ¶ 6, ECF No. 1 at Page ID 3-6.)
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Examples:
J.A. at 182.
R. 24.
[R. at 7].
<Name of document> <pincite> , <Citation to case in which document was filed> (<docket
number in parenthesis>), <optional commercial database identifier or webpage URL>.
Example:
Compl. 5, Parsell v. Shell Oil Co., 421 F. Supp. 1275 (D. Conn. 1976) (Civ. No. B-700).
Pl.’s Resp. to Defs.’ Mot. for Summ. J. 14, Martinez-Mendoza v. Champion Int’l Corp., 340
F.3d 1200 (11th Cir. 2003) (No. 06-19139).
Brief for Brendan Keefe in His Official Capacity as Investigative Reporter for 11Alive Atlanta,
and WXIA-TV as Amici Curiae in Support of Respondent, Georgia v. Public.Resource.org, Inc.,
140 S. Ct. 1498 (2020) (No. 18-1150), 2019 WL 5391110.
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D. COURT & LITIGATION DOCUMENTS
Examples:
Compl. ¶ 2, Jones v. Smith, No. 09-230 (9th Cir. Apr. 17, 2015), ECF No. 2.
Pet. for Writ of Cert. at 6, Crowe v. Ore. St. Bar, No. 20-1678 (May 27, 2021),
https://www.scotusblog.com/case-files/cases/crowe-v-oregon-state-bar/.
Examples:
Oral Argument at 32:50, Georgia v. Public.Resource.org, 140 S. Ct. 1498 (2020) (No. 18-1150),
https://www.oyez.org/cases/2019/18-1150.
Transcript of Oral Argument at 5, Ramos v. Louisiana, 140 S. Ct. 1390 (2020) (No. 18-5924),
https://www.supremecourt.gov/oral_arguments/argument_transcripts/2019/
18-5924_4gcj.pdf.
Examples:
Pl.’s Resp. to Defs.’ Mot. for Summ. J. at 14, Martinez- Pl.’s Resp. to Defs.’ Mot. for Summ. J.
Mendoza v. Champion Int’l Corp., 340 F.3d 1200 (11th at 14, Martinez-Mendoza, 340 F.3d
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Examples:
The Court held that the Official Code of Georgia Annotated is a government edict that cannot
be copyrighted by the State of Georgia.
The Aalmuhammed court explained that the word author “is traditionally used to mean the
originator or the person who causes something to come into being.”
This Court is being asked to expand the definition of “author” far beyond the statutory text.
The Plaintiff does not have a cognizable copyright interest in her acting performance.
In Bobbs-Merrill, the plaintiff-copyright owner sold its book with a printed notice announcing
that any retailer who sold the book for less than one dollar was liable for copyright
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D. COURT & LITIGATION DOCUMENTS
infringement.
Example:
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R28.1 General
A full citation to a book or other non-periodical is made up of the following elements:
• Volume number (if the book is in a set of more than one volume)
• Author name or names
• Title of the Publication
• Parenthetically, edition and editor information, if applicable; and year
Examples:
Lawyers in Practice: Ethical Decision Making in Context (Leslie C. Levin & Lynn Mather eds.,
2012).
Joseph Williams & Joseph Bizup, Style: Ten Lessons in Clarity and Grace (12th ed. 2016).
In general, list the names of the authors as listed on the publication, such as by including listed
first names and middle initials in addition to surnames. Use titles that follow an author’s name
(Sr.) but not titles that precede them (Hon.)
For two authors, list them in the same order as on the publication separated by “&.” For more
than two authors, you may list all of the authors with “&” before the last. Or you may use “et
al.” after the first-named author.
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E. BOOKS & NON-PERIODICALS
INDIGO INKLING
The “et al.” option for books and law review articles with multiple authors may be a space-
saving option, but it may also effectively erase the contribution of co-authors other than the
first-named. This citation erasure may occur qualitatively (in how the article is
remembered) and/or quantitatively (in various empirical citation rankings). University of
Pennsylvania Law School professor Dave Hoffman has argued that all authors should be
included in the full citation, and indeed a number of law reviews have rejected the et al.
option. Professor Hoffman calls this approach the “Fair Citation Rule. ”
Short-forms for books and law review articles may be based on just the first-named author,
an approach consistent with the spirit of efficient short-form citations. But the Fair Citation
Rule can be followed in short citations as well, an approach that is less efficient but more
representative of the work.
R28.2.4 Pincite
Include the exact page number being cited immediately after the name of the publication. Do
not use “at” before the pincite in a full citation. When citing a work organized using sections or
paragraphs, use those instead, adding a page number only if helpful.
Example:
Marc A. Franklin et al., Mass Media Law Cases and Materials 472 (8th ed. 2011).
The full citation to a book publication has up to four elements in the required parenthetical, in
the following order:
If listing an editor or a translator, then follow the name with the designation “ed.,” or “trans.,”
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respectively. Do not place a comma before the designation of ed. or trans., but do include a
comma after that designation and before the year of publication.
Examples:
Gabriel García Márquez, One Hundred Years of Solitude (Gregory Rabassa trans., Harper &
Row 2003) (1967).
Roger Angell, This Old Man, in The Best American Essays 2015 (Ariel Levy & Robert Atwan
eds., 2015).
R29.1 Id.
Id. may be used for references to books or non-periodical material cited in the immediately
preceding citation, assuming that citation contains only one source. Update the page number
you’re referring to within that source, as needed, by using “Id. at <x>.”
Do not use id. for internal cross references, or for citing back to a body of collected works when
actually citing a single work from that body.
R29.2 Supra
Use “supra” when you’ve used the full citation before, but it’s not the immediately preceding
citation. Use a shortened title if you cite to multiple sources from the same author. Where a
source has more than two authors, short citation forms using supra may use the first-named
author and “et al.” to refer to other named authors, regardless of whether the first full citation
has done so. You may retain all the authors if desired for giving credit.
The short form supra can be used in references to an earlier-cited work where “id.” does not
apply. Citations built using supra should include:
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E. BOOKS & NON-PERIODICALS
Examples:
B.F. Skinner, Beyond Freedom and Dignity 32 (2002). Id. at 21. Skinner, supra, at 21.
3 Melville Nimmer & David Nimmer, Nimmer on See id. § See Nimmer & Nimmer,
Copyright § 12.01 (Rev. ed. 2015) 14.02. supra, § 14.02
Graham C. Lilly et al., Principles of Evidence 122 (6th ed. Id. at Lilly, supra, at 90
2012) 88–103
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Citations to consecutively paginated journals (that is, journals in which page numbering is
continued from the last issue) take the following form:
<Author’s Name(s)>, <Italicized Title of the Article>, <volume number, if applicable> <Name
of Publication, abbreviated> <page number of first page of article cited>, <pincite, if citing to
specific point> <(year published)>.
Follow Rule R30.2 below for author name rules and Rule R30.3 for abbreviating the name of
the publication.
Example:
Liz Brown, Bridging the Gap: Improving Intellectual Property Protection for the Look and
Feel of Websites, 3 N.Y.U. J. Intell. Prop. & Ent. L. 310, 351 (2014).
Citations to journals and magazines with standard pagination (that is, where pagination re-
starts for every issue) take the following form:
Example:
Jack Dickey, The Power of Taylor Swift, Time, Nov. 24, 2014, at 13.
A pincite to a specific page may be added after the page number of the article’s first page, in the
following form: , <pincite>.
Example:
Jack Dickey, The Power of Taylor Swift, Time, Nov. 24, 2014, at 13, 17.
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F. JOURNALS, MAGAZINES, & NEWSPAPER ARTICLES
Citations to material written by students in law journals such as comments and notes take the
following form:
<Author’s Name(s), if signed with more than initials>, <Designation of Piece>, <Italicized Title
of the Article>, <volume number, if applicable> <Name of Publication, abbreviated> <page
number of first page of article cited>, <pincite, if citing to specific point> <(year published)>.
Examples:
Amanda Levendowski, Note, Using Copyright to Combat Revenge Porn, 3 N.Y.U. J. Intell.
Prop. & Ent. L. 422 (2014).
Victoria Nemiah, Note, License and Registration, Please: Using Copyright “Conditions” To
Protect Free/Open Source Software, 3 N.Y.U. J. Intell. Prop. & Ent. L. 358, 361 (2014).
Comment, Law and Lawns: Mandatory Water Restrictions and Substantive Due Process, 7
Calif. L. Rev. 138 (1972).
INDIGO INKLING
Many sources such as newspapers and magazines are available both in a traditional hard-
copy publication and an online format. Although the online site is almost certainly easier to
find and read, traditional legal citation prioritizes the hard-copy publication for law
reviews, magazines, and similar periodical sources. Newspapers are treated differently as
shown in Rule R30.4.
R30.2 Authors
R30.2.1 Name as listed
Show the author’s name beginning with first name, initials if indicated on the publication, and
last name followed by any name suffixes (Jr., III) indicated on the publication title.
For two authors, indicate their names in the order shown on the publication, separated by an
ampersand. Do not insert a comma before the ampersand.
For more than two authors, all authors may be listed with an ampersand before the last name;
or all but the first may be omitted and replaced by “et al.” Indicate all authors when relevant
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When no author is listed at the beginning or end of the publication source, skip the author field
and begin the citation with the publication’s title.
Use the abbreviations for common institutional names as listed in Table T15 if the name is
listed. If the institutional name is not listed in Table T15, use abbreviations as listed in Table
T11 and Table T12. If the periodical title has an abbreviation in it, use the abbreviation. If the
word is not found in any of these tables, do not abbreviate the word in the abbreviated title.
For journals not listed in the tables, streamline the journal title with these grammar
mechanics. Do not use the words “a,” “at,” “in,” “of,” and “the” in the abbreviated title. Do,
however, use the word “on.” If the title consists of “a,” “at,” “in,” “of,” or “the” followed by a
single word, do not abbreviate the remaining word. Omit all commas in abbreviated titles, but
retain other punctuation. If a periodical title has a colon followed by words, omit all that from
the abbreviated title.
Use discretion to format a journal title differently when the journal identifies its own
abbreviated title differently, particularly for legal journals (as opposed to those from other
disciplines using other citation conventions).
Examples:
To cite an online supplement to a print publication, use the proper abbreviation for the print
publication, followed by the name of the online supplement.
If a periodical has been renumbered into a new series, indicate that by prefacing the series
number with “(n.s.)”. Use the title of the periodical on the issue you are citing, even if the name
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F. JOURNALS, MAGAZINES, & NEWSPAPER ARTICLES
Citations to newspaper articles take the following form: <Author’s Name(s), if signed>,
<Italicized Title of the Article>, <Name of Publication, abbreviated>, <full date of
publication>, at <number of first page of article>. Add a designation after the author’s name
such as “editorial,” where appropriate.
Examples:
Charlie Savage, U.N. Commission Presses U.S. on Torture, N.Y. Times, Nov. 14, 2014, at A6.
Vikas Bajaj, Editorial, Rules for the Marijuana Market, N.Y. Times, Aug. 5, 2014, at A20.
Examples:
Charlie Savage, U.N. Commission Presses U.S. on Torture, N.Y. Times (Nov. 14, 2014),
https://www.nytimes.com/2014/11/14/world/europe/un-commission-presses-us-on-
torture.html.
Vikas Bajaj, Editorial Rules for the Marijuana Market, N.Y. Times (Aug. 5, 2014),
https://www.nytimes.com/2014/08/05/opinion/high-time-rules-for-the-marijuana-
market.html.
R31.1 Id.
Use “id.” when referring to the source cited in the immediately preceding citation. Id. can be
used to refer to the same source as in a preceding citation that is itself also id., but do not
repeat id. more than four times sequentially. After the fourth id., add more information by
repeating the full citation or providing a short citation with supra.
Id. may be used by itself to indicate the same page of the same source, or with “at” to indicate a
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R31.2 Supra
Use “supra” when you’ve used the full citation before, but it’s not right next to the sentence you
will provide the citation for now. Use a shortened title if you cite to multiple sources from the
same author. Where a source has more than two authors, short citation forms using supra may
use the first-named author and “et al.” to refer to other named authors, regardless of whether
the first full citation has done so. You may retain all the authors if desired for giving credit.
Example (footnote):
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G. INTERNET SOURCES
G. INTERNET SOURCES
• Authenticated copy: source that uses some authenticating tool, such as a digital
signature. This is generally the preferred version.
• Official copy: version of document designated “official” by a federal, state, or local
government.
• Exact copy: unaltered online reproduction of the entirety of a printed source, including
pagination.
Example:
Daniel E. Ho & Frederick Schauer, Testing the Marketplace of Ideas, 90 N.Y.U. L. Rev. 1160,
1175 (2015), http://www.nyulawreview.org/sites/default/files/pdf/
NYULawReview-90-4-Ho_Schauer.pdf.
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INDIGO INKLING
Even in an online world, the format of the printed page reigns supreme in legal citation.
Thus, when a document is available in multiple formats, choose the citation format that
best preserves the document as it would display if printed. For example, PDF is preferred
over HTML. The benefit of these citations is allowing citations to specific page numbers (for
pincites) regardless of whether it is being viewed digitally or in print.
Note that many of the Internet citation rules are little more than common sense (that’s a
compliment, not a dig). For example: include the URL that most directly links your reader
to the authority, as you don’t want to send readers on a wild goose chase through the
recesses of the Internet in search of a source. For the sake of completeness, we include these
rules below, even though most people would probably intuit them.
One internet citation rule is not common sense, however. Traditional legal citation does not
underline the URL to indicate a hyperlink. (Indeed, if you are using italics for case names,
titles, and such, nothing will be underlined anywhere in the document.) As you create a
citation to an internet source, your word processor may helpfully add an underlined
hyperlink with URL text turned a different color. For citation per the Uniform System of
Citation, believe it or not, you should remove that formatting change. Depending on the
situation, you might choose to leave the non-compliant (yet helpful) obvious hyperlink. You
could remove the hyperlink altogether. Or you could change the formatting so the hyperlink
works but is rendered in plain font, consistent with traditional legal citation.
When available, use the name or names of the individual, personal authors of the source.
Example:
Kate Klonick, Facebook v. Sullivan, Knight First Amend. Inst. (Oct. 1, 2018), https://
knightcolumbia.org/content/facebook-v-sullivan.
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G. INTERNET SOURCES
Examples:
The Pew Charitable Trusts, How Debt Collectors Are Transforming State Courts, Pew (May 6,
2020), https://www.pewtrusts.org/-/media/assets/2020/06/debt-collectors-to-
consumers.pdf
For web posts and comments, use the actual name of the post author, or the username of the
post author if the actual name is not available. For comments, the author of the comment
should be included if available, but the author of the original post need not be cited.
If the name of the author is unavailable in each of the above forms, it may be omitted from the
basic formula.
Include the particular cited webpage as the source title (roughly equivalent to citing the title of
an article). This title should be based on either the title bar or the heading of that page as
viewed in the browser.
Examples:
Mike Masnick, Left Shark Bites Back: 3D Printer Sculptor Hires Lawyer to Respond to Katy
Perry’s Bogus Takedown, TechDirt (Feb. 9, 2015, 12:27 PM), https://www.techdirt.com/
articles/20150209/11373729960/left-shark-bites-back-3d-printer-sculptor-hires-lawyer-to-
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respond-to-katy-perrys-bogus-takedown.shtml.
The content title should be informative but not unduly long, if possible without compromising
clarity and precision.
Include the title of certain pages linked from main website when relevant, including postings,
comments, and titles of subheadings (in italics). Where relevant, as in comments, subheadings
should indicate their relationship to the page to which they are responsive.
Example:
Nasch, Re: Costumes, IP, and Ownership Rights, Comment to Left Shark Bites Back, TechDirt
(Feb. 14, 2015, 9:55 AM), https://www.techdirt.com/articles/20150209/11373729960/left-
shark-bites-back-3d-printer-sculptor-hires-lawyer-to-respond-to-katy-perrys-bogus-
takedown.shtml.
R33.3.2 Abbreviation
Title should be abbreviated per Table T11, Table T12, and Table T15.
Example:
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G. INTERNET SOURCES
R33.4 Pincite
R33.4.1 Paginated electronic publication, or publication of print version
Include when an electronic document preserves the pagination of a printed version. Cite to
pages as they would appear on the document if printed.
Example:
James Huguenin-Love, Song on Wire: A Technical Analysis of ReDigi and the Pre-Owned
Digital Media Marketplace, 4 N.Y.U. J. Intell. Prop. & Ent. L. 1, 4 (2014),
http://jipel.law.nyu.edu/wp-content/uploads/2015/02/JIPEL-Winter-2014-Edition.pdf.
Examples:
Laura Moy, Public Knowledge & Consumers Petition Copyright Office for Right to Unlock
Access to Their Own Stuff, Public Knowledge Blogs (Nov. 3, 2014),
https://www.publicknowledge.org/news-blog/blogs/public-knowledge-consumers-petition-
copyright-office-for-right-to-unlock-ac.
Chris Cillizza, Winners and Losers of the 2014 Midterm Elections, Wash. Post Blogs (Nov. 5,
2014, 10:25 AM), http://www.washingtonpost.com/blogs/the-fix/wp/2014/11/04/winners-
and-losers-of-the-2014-election-early-edition/.
Omit time if the source is not updated throughout the day or if there is no time listed.
If no date is provided, add a parenthetical indicating the “last modified” or “last updated” date
for the URL, or, if none of the above are provided, use the “last visited” date. Any date cited in
one of these three formats should be placed after the URL in the citation.
Example:
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R33.6 URL
R33.6.1 Entire URL preferred
Cite in its entirety unless the URL is especially long or unwieldy (a very high standard, given
how long most URLs are).
R33.6.2
If the URL is too long and unwieldy, cite just to the root URL and include a parenthetical
directing the user to the specific material cited.
Example:
When helpful (such as to preserve a site that may change or to preserve a site for future
readers), include URL to an archived version of the webpage in brackets.
Example:
Kevin Underhill, Gollum Experts to Testify, Says Court, Lowering the Bar (Dec. 4, 2015),
http://www.loweringthebar.net/2015/12/gollum-experts.html [https://web.archive.org/web/
20151208124302/http://www.loweringthebar.net/2015/12/gollum-experts.html].
When a website is served by multiple URLs, use the primary one. When a source is published
on multiple URLs (such as a law-firm website and a content aggregator), use the most
authoritative and original website.
Example:
American Bar Association (@ABAesq), Twitter (July 6, 2021, 8:11 PM), https://twitter.com/
ABAesq/status/1412564952846581761?s=20.
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G. INTERNET SOURCES
A bracketed parenthetical also may also be used to provide a short-form definition, if needed to
avoid ambiguity or to preserve clarity. When citing directly to Internet sources, the
“hereinafter” bracketed parenthetical should come right after the URL or, if applicable, the
“last visited” parenthetical.
Chris Cillizza, Winners and Losers of the 2014 Midterm Elections, Wash. Post Blogs (Nov. 5,
2014, 10:25 AM), http://www.washingtonpost.com/blogs/the-fix/wp/2014/11/04/winners-
and-losers-of-the-2014-election-early-edition/.
Cillizza, supra.
Full Citation: Ohio’s Official Online Publication of State Laws and Regulations,
https://codes.ohi (last visited July 6, 2021) [hereinafter, “Ohio Official Online State Laws”].
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H. TABLES
T1 Federal Materials
United States Supreme Court (U.S.): Cite to U.S., if possible. If not, cite to S. Ct. If that’s
not possible, cite to L. Ed. If you can cite to none of the above, cite to U.S.L.W.
Circuit Justices (e.g., Gorsuch, J., in chambers): Cite to U.S. if possible; otherwise, cite to S.
Ct., L. Ed., or U.S.L.W. in that order of preference.
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Some cases presided over by Circuit Justices are found in other reporters. After the citation,
indicate the Circuit Justice and applicable circuit parenthetically as in this example: (Jackson,
Circuit Justice, 2d Cir. 1950).
United States Courts of Appeals (1st Cir., 2d Cir., 3d Cir., 4th Cir., 5th Cir., 6th
Cir., 7th Cir., 8th Cir., 9th Cir., 10th Cir., 11th Cir., and D.C. Cir.): Cite to F., F.2d,
F.3d, or F.4th
Circuit Courts (e.g., C.C.S.D.N.Y., C.C.D. Cal.) (abolished 1912): Cite to F. or F. Cas.
Temporary Emergency Court of Appeals (Temp. Emer. Ct. App.) (1971–1993), Emergency
Court of Appeals (Emer. Ct. App.) (created 1942, abolished 1961), and Commerce Court
(Comm. Ct.) (created 1910, abolished 1913): Cite to F. or F.2d.
United States Court of Appeals for the Federal Circuit (Fed. Cir.) (created 1982),
successor to the United States Court of Customs and Patent Appeals (C.C.P.A.) (previously the
Court of Customs Appeals (Ct. Cust. App.)) and the appellate jurisdiction of the Court of
Claims (Ct. Cl.): Cite to F., F.2d, F.3d, or F.4th; else, cite to the official reporter.
United States Court of Federal Claims (Fed. Cl.) (created 1992), formerly United States
Claims Court (Cl. Ct.) (created 1982), and successor to the original jurisdiction of the Court of
Claims (Ct. Cl.): Cite to one of the following reporters:
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Reporter
1960–1982 F.2d
United States Court of International Trade (Ct. Int’l Trade) (created 1980), formerly
United States Customs Court (Cust. Ct.) (created 1926): Cite to the official reporters, if
possible; if not, in the following order, cite to F. Supp., F. Supp. 2d, or F. Supp. 3d to Cust. B. &
Dec. (an official publication), or to I.T.R.D. (BL).
District Courts (e.g., D. Mass., S.D.N.Y.): Cite F. Supp., F. Supp. 2d, F. Supp. 3d, F.R.D., or
B.R.
If the case is not published in the priority reporters above, cite to Fed. R. Serv., Fed. R. Serv.
2d, or Fed. R. Serv. 3d. For cases before 1932, cite to F., F.2d, or F. Cas.
Use Table T9 for court abbreviations and Table T12 for geographical abbreviations to construct
the proper abbreviation for the District Court, such as C.D. Cal. and D.N.M.
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Example: Davey v. The Mary Frost, 7 F. Cas. 11 (E.D. Tx. 1876) (No. 3591).
Bankruptcy Courts and Bankruptcy Appellate Panels (e.g., Bankr. N.D. Cal.; B.A.P.
1st Cir.), cite to B.R.; else, cite to a looseleaf service.
Judicial Panel on Multidistrict Litigation (J.P.M.L.) (created 1968) and Special Court,
Regional Rail Reorganization Act (Reg’l Rail Reorg. Ct.) (created 1973): Cite to F. Supp., F.
Supp. 2d., or F. Supp. 3d.
Tax Court (T.C.) (created 1942), previously Board of Tax Appeals (B.T.A.), cite to T.C. or
B.T.A.; else, cite to T.C.M. (CCH), T.C.M. (P-H), T.C.M. (RIA), or B.T.A.M. (P-H).
United States Court of Appeals for Veterans Claims (Vet. App.), previously United
States Court of Veterans Appeals (Vet. App.) (created 1988), cite to Vet. App.
United States Court of Appeals for the Armed Forces (C.A.A.F.), previously United
States Court of Military Appeals (C.M.A.): Cite to C.M.A.
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Military Service Courts of Criminal Appeals (A. Ct. Crim. App., A.F. Ct. Crim. App., C.G.
Ct. Crim. App., N-M. Ct. Crim. App.), previously Courts of Military Review (e.g., A.C.M.R.),
previously Boards of Review (e.g., A.B.R.): For cases after 1950, cite to M.J. or C.M.R. For
earlier cases, cite to the official reporter.
Session laws
United States Statutes at Large <vol. no.> Stat. <page no.> (<year>)
For public laws before 1957, cite by chapter number; for subsequent public laws, cite by public
law number.
Note that the year of the code section is not required, but may be included if appropriate to the
citation context. The exact date of the unofficial publisher’s “current through” date may also be
provided if relevant and helpful to the citation context.
Decisions: Cite decisions as: <case name>, ASBCA No. <decision number>, <citation to
110
H. TABLES
Administrative Materials
services> For citations to the Board of Contract Appeals Decisions (BCA), published by
Commerce Clearing House, the publisher is not indicated and the volume number should be
used to indicate the year of the decision.
Example: RMTC Sys., Inc., ASBCA No. 43466, 93-1 BCA ¶ 25,508.
Decisions: Cite the same way as a citation for the Armed Services Board of Contract Appeals,
but include the opposing agency in the case name.
Example: G2G, LLC v. Dept. of Commerce, CBCA 4845-R, 15-1 BCA ¶ 36,163.
Decisions: Cite decisions as: <case name>, ASBCA No. <decision number>, <citation to
services> For citations to the Board of Contract Appeals Decisions (BCA), published by
Commerce Clearing House, the publisher is not indicated and the volume number should be
used to indicate the year of the decision.
Decisions: Cite as <case name>, CFTC No. <docket number>, <secondary source if
available> (<date>).
Example: Windjammer Capital LLC v. Glob. Futures Exch. & Trading Co., Inc., CFTC No.
14-R1, 2015 WL 9434227 (Dec. 22, 2015).
Decisions: Cite as <case name>, CFPB No. <decision number>, <secondary source if
available> (<date>).
Example: American Express Travel Related Servs., Inc., CFPB No. 2013-CFPB-0013 (Dec. 24,
2013).
Example: Arizona Livestock Auction, Inc., 55 Agric Dec. 1121 (U.S.D.A. 1996).
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Directives: Cite as: <issuing agency abbreviated according to table below> <directive
number>, <directive title> (U.S.D.A. <year>).
Forest Service FS
Rural Development RD
112
H. TABLES
Administrative Materials
Management Act: Decision and Findings in the Consistency Appeal of <party name>, from an
objection by <state or relevant state agency’s name> (Sec’y of Commerce <date>). If these
decisions are not published in an official reporter; indicate the source where the decision is
located.
Other NOAA Decisions: For decisions of administrative law judges in civil administrative
law cases, cite to the Ocean Resources and Wildlife Reporter (O.R.W.); else cite to an
appropriate secondary source.
For decisions of the Patent Trial and Appeal Board (P.T.A.B.), cite as <case name>, No.
<docket number>, <citation to secondary source> (P.T.A.B. <year>).
Use the U.S.P.Q.2d as the preferred secondary source in these citations if available, rather than
a commercial database.
For decisions of the Patent Trial and Appeal Board that are not published but available on a
website or otherwise, cite as Ex parte <Name>, decision of the Patent Trial and Appeal Board,
Patent No. <case xxx,xxx,xxx>, paper No. <xxx>, <xxx> pages. See Manual of Patent
Examining Procedure 707.06.
For decisions of the Trademark Trial and Appeal Board (T.T.A.B.), cite as: <case name>,
<citation to secondary source> (T.T.A.B. <year>).
Use the U.S.P.Q.2d as the preferred secondary source in these citations if available, rather than
a commercial database.
Pre-Sept. 16, 2012: For decisions by the Board of Patent Appeals and Interferences (B.P.A.I.),
cite as: <party name>, No. <docket number>, <citation to secondary source if available>
(B.P.A.I. <date>).
Patents:
Cite the patent number and the date the patent was filed.
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Administrative Materials
System for disseminating media content representing episodes in a serialized sequence, U.S.
Patent No. 8,112,504 B2 (filed Mar. 4, 2009) (issued Feb. 7, 2012)
For citations to a specific field of the title page, include the field code in brackets.
Example: U.S. Patent No. 8,112,504 B2, at [75] (filed Mar. 4, 2009)
For citations to a specific portion of patent text, a patent figure, or an item within a figure.
Example: U.S. Patent No. 8,112,504 B2, fig. 1, item 141 (filed Mar. 4, 2009)
Short form patent citations include an apostrophe followed by the last three digits of the patent
number.
Trademarks:
For trademarks that have been filed, but not approved, cite as U.S. Trademark Application
Serial No. <Serial Number> (filed <date>).
Example: U.S. Trademark Application Serial No. 86,680,743 (filed Jul. 1, 2015).
Official Gazette of the United States Patent Office (1872–1971)Off. Gaz. Pat. Office
Official Gazette of the United States Patent and Trademark Off. Gaz. Pat. & Trademark
Office (1975–2002) Office
Department of Education
Example: Institute of Education Sciences, National Board for Education Sciences Annual
114
H. TABLES
Administrative Materials
Report 12 (2014).
Reports: Cite federal student aid proceedings as <case name>, U.S. Dep’t of Educ., No.
<docket number> (<date>).
Example: Lincoln Univ., U.S. Dep’t of Educ., No. 13-68-SF (Mar. 16, 2015).
The two official reporters of the Bureau of Customs and Border Protection and its predecessors
are the Administrative Decisions Under Immigration and Nationality Laws (I. & N. Dec.) and
the Customs Bulletin and Decisions (Cust. B. & Dec).
Department of Justice
Advisory Opinions: For published, formal advisory opinions, cite in the same manner as
adjudications. Cite opinions from the Attorney General as Opinions of the Attorneys General
(Op. Att’y Gen.).
Cite opinions from the Office of Legal Counsel as Opinions of the Office of Legal Counsel of the
Department of Justice (Op. O.L.C.).
Examples:
Authority of Sec’y of Treasury to Compromise Final Judgments, 36 U.S. Op. Att’y Gen. 40
(1929)
Diversion of Water from Niagara River, 30 Op. Att’y Gen. 217 (1913).
U.S. Assistance to Countries that Shoot Down Civil Aircraft Involved in Drug Trafficking, 18
Op. O.L.C. 148, 165 (1994).
Department of Labor
Decisions in Petition for Modification Cases Under Section 101(c) of the Mine Act,
30 U.S.C. § 811(c): Cite as <description of decision>, <case name>, Docket No. <docket
number> (Dep’t of Labor <date>).
Note that these decisions have not been reported in any official reporter or service.
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Administrative Materials
Note that these decisions have not been reported in any official reporter or service.
Example: OFCCP v. Bank of Am., 97-OFC-16, Secretary's Decision and Order of Remand
(Dep't of Labor Mar. 31, 2003).
Example: Jones v. I.T.O. Corp. of Baltimore, 9 Ben. Rev. Bd. Serv. (MB) 583, 585 (1979).
Example: U.S. Dep’t of Labor, Wage and Hour Div., Opinion Letter FLSA2021-2 (Jan. 8,
2021), https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/
2021_01_08_02_FLSA.pdf.
Cite agency decisions to Interior Decisions (Interior Dec.) or Interior and General Land Office
Cases Relating to Public Lands (Pub. Lands Dec.). Where a board within the agency issues the
opinion, note the board in the same parenthetical as the date, using these abbreviations:
Department of State
Reports: For reports of the Bureau of Democracy, Human Rights, and Labor, cite as: U.S.
Dep’t of State, Bureau of Democracy, H.R. and Lab., <title> <page> (<date>).
Example: U.S. Dep’t of State, Bureau of Democracy, H.R. and Lab., International Religious
Freedom Report 14 (2014).
Regulations: For Department of Treasury regulations, cite as <Treas. Reg.>, despite the fact
that they are published under Title 26 of the C.F.R.
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H. TABLES
Administrative Materials
Indicate if the regulation is a temporary regulation by beginning the citation with Temp:
If any subsection of the cited section has been amended or appears in substantially different
versions, give the year of the most recent amendment. Follow this rule even if the particular
subsection you are citing has never been amended.
For proposed Treasury regulations to the Federal Register, cite in the following manner:
Example: Prop. Treas. Reg. § 1.704-1, 48 Fed. Reg. 9871, 9872 (Mar. 9, 1983).
The abbreviations used are explained in the introductory pages of each volume of the
Cumulative Bulletin.
Private Letter Rulings: Cite by number and the date issued, if available.
Technical Advice Memoranda: Cite by number and the date issued, if available.
General Counsel Memoranda: Cite by number and the date on which the memorandum
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was approved.
Other Treasury Determinations: For all other Treasury materials, cite to the Cumulative
Bulletin, Internal Revenue Bulletin, or Internal Revenue Manual (IRM).
Cases: For the Tax Court and Board of Tax Appeals, cite as those of a court, not of an agency.
Acquiescence: The following may be indicated in the case citation if the Commissioner of the
Internal Revenue Service has published an acquiescence (acq.), acquiescence in result only
(acq. In result), or nonacquiescence (nonacq.) in a decision of the Tax Court or Board of Tax
Appeals.
Decisions: For EEOC decisions that do not have readily identifiable titles, cite using the
decision number in place of the title. Otherwise cite per Rule 19.3.
For EEOC Federal Sector decisions that have party names, cite in accordance with Rule 11.2.
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H. TABLES
Administrative Materials
Other Presidential Papers: Cite to Public Papers of the Presidents (Papers) if found there.
If not recorded in the Public Papers, cite the Weekly Compilation of Presidential Documents
(Weekly Comp. Pres. Doc.), published from 1965 to January 29, 2009, the Daily Compilation
of Presidential Documents (Daily Comp. Pres. Doc.), published from January 29, 2009 to date,
or the U.S. Code Congressional and Administrative News (U.S.C.C.A.N.).
Example: Office of Mgmt. & Budget, Exec. Office of the President, Budget of the United
States Government, Fiscal Year 2014 (2013).
Decisions: For decisions of administrative law judges in civil penalty enforcement matters
adjudicated under 14 C.F.R. pt. 13, § 13.16 and subpart G, cite per Rule R12.4 as slip opinions.
For Decisions of the Administrator or his delegate, cite using an order number, not a docket
number.
For Decisions of the Office of Dispute Resolution for Acquisition (ODRA) adjudicated under 14
C.F.R. Part 17, the citation should incorporate the type of dispute.
For other FAA decisions and orders, the citation should indicate the nature of the decision,
followed by the date.
Examples:
Federal Express Corporation, FAA Order No. 2002-20, 2002 WL 31777976 (F.A.A.).
Envirosolve, LLC, FAA Order No. 2006-2, 2006 WL 465371 (Feb. 7, 2006).
Aerocomp, Inc., FAA Order No. 2006-1, Order Dismissing Appeal (Jan. 12, 2006).
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Administrative Materials
1934-1986, or the Federal Communications Commission Record (FCC Rcd.), published since
1986.
Example: Protecting and Promoting the Open Internet, GN Docket No. 14-28, Notice of
Proposed Rulemaking, 29 FCC Rcd 5561 (2014).
Example: Filing of Privileged Materials and Answers to Motions, Order No. 769, 141 FERC ¶
61,049 (2012).
Cite decisions to the Decisions of the Federal Labor Relations Authority (F.L.R.A.).
Cite decisions to the Federal Mine Safety and Health Review Commission Decisions
(FMSHRC).
Enforcement Actions: Cite written agreements resulting from enforcement actions as:
Written Agreement between <private bank name> and <Federal Reserve Bank name>, Docket
no. <docket number> (<date>).
Example: Written Agreement Between Allied First Bancorp, Inc. and Federal Reserve Bank of
Chicago, Docket No. 14-006-WA/RB-HC (2014).
Bid Protest Decisions: Cite to Decisions of the Comptroller General of the United States
(Comp. Gen.).
For unpublished decisions to a readily accessible source, cite as: <protesting party>, <docket
number>, <volume number or year> <source> <location within source volume or year>
(Comp. Gen. <date>).
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H. TABLES
Administrative Materials
Do not indicate the publisher when citing these cases to the Comptroller General’s
Procurement Decision, published by West.
Examples:
HP Enterprise Services, LLC, B-405692, 2012 CPD ¶ 13 (Comp. Gen. Dec. 14, 2011).
Phoenix Environmental Design, Inc., B-412503, 2016 WL 873296 (Comp. Gen. Mar. 7, 2016).
Insert “et al.” after the docket number where a decision resolves multiple bid protests, each
having its own docket number.
Example:
IAP-Hill, LLC, B-406289 et al, 2012 CPD ¶ 151 (Comp. Gen. Apr. 4, 2012).
Trade Remedy Investigations: Cite as: <investigation name>, Inv. No. <number>, USITC
Pub. <number> (<date>) (<status>).
Examples:
Trade and Investment Polices in India, 2014–2015, Inv. No. 332-550, USITC Pub. 4566 (Sep.
2015).
The Year in Trade 2014: Operation of the Trade Agreements Program, USITC Pub. 4543 (July
2015).
Polyvinyl Alcohol from China, Japan, and Taiwan, Inv. Nos. 701-TA-309, 731-TA-528,
731-TA-529, USITC Pub. 4067 (Mar. 27, 2009) (Review).
Cite decisions to the Decisions of the United States Merit Systems Protection Board
(M.S.P.B.).
Cite decisions and orders to the Decisions and Orders of the National Labor Relations Board
(N.L.R.B.).
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Cite decisions to the National Transportation Safety Board Decisions (N.T.S.B.), published
from 1967-1977.
For decisions of the Nuclear Regulatory Commission, cite to the Nuclear Regulatory
Commission Issuances (N.R.C.).
For decisions of its predecessor, the Atomic Energy Commission (1956–1975), cite to the
Atomic Energy Commission Reports (A.E.C.).
Decisions: For commission decisions reported in a service, cite as: <party name>, <service
volume number> <publisher> <service, abbreviated as below> <page/paragraph number>
(No. <docket number>, <year>).
At the end of a citation, indicate parenthetically when an administrative law judge issued the
decision, rather than the commission.
Example: Miller Construction Co., 24 BL OSHC 1817 (No. 13-0323, 2013) (ALJ).
The abbreviations OSHRC uses for services reporting its decisions vary from those in Table T4
as follows:
A decision that is not cited in any service or database may be cited as an unpublished slip
opinion following the format in Rule R12.4.
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H. TABLES
Administrative Materials
Examples:
MP Environmental Funding LLC, SEC Interpretive Letter, 2007 WL 2838964 (Sep. 19, 2007)
Releases: Cite the Federal Register, SEC Docket, or a loose-leaf service. Releases that have
subject-matter title may be presented in a short form. Make sure to include the act under
which the release was issued, the release number, and the date.
Example: SEC Whistleblower Rules, Exchange Act Release No. 75592, 80 Fed. Reg 47829
(Aug. 10, 2015).
If the release is an adjudication, abbreviate the parties’ names according to Rule 11.
Example: Midas Sec., LLC, Exchange Act Release No. 66200, 102 SEC Docket 3123, 102 SEC
Docket 3137 (Jan. 20, 2012).
If the adjudication occurred before an administrative law judge, indicate this fact in the date
parenthetical.
If a particular release is issued under the Securities Act, the Exchange Act, or the Investment
Company Act, a parallel citation should be given in that order.
Staff Interpretations: Cite SEC Staff Accounting Bulletins, Staff Legal Bulletins, and
Telephone Interpretations as follows:
Example: SEC Staff Accounting Bulletin No. 99, 64 Fed. Reg. 45150 (Aug. 19, 1999).
SEC Filings: For annual reports, proxy statements, and other company filings required under
federal securities laws, provide the name of the company (abbreviated according to Rule 15),
the title as given in the document, the form type in parentheses, the page number if applicable,
and the full date of filing with the SEC.
Example: Apple Inc., Annual Report (Form 10-K), (Oct. 28, 2015).
If citing annual reports, proxy statements, or other documents in a form other than that filed
with the SEC, treat as books under Rule 15.
Decisions: Cite decisions as: <party name>, SBA No. <docket number> (<date>).
Example: OxyHeal Medical Systems, Inc., SBA No. SIZ-5707 (Jan. 19 2016).
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Rulings and Acquiescence Rulings: For Social Security Rulings, cite as SSR; for Social
Security Acquiescence Rulings, cite as SSAR.
Cite to the Social Security Rulings, Cumulative Edition (S.S.R. Cum. Ed.). If not published
there, cite to another official source, such as the Code of Federal Regulations or the Federal
Register. Otherwise, cite a commercial database or other source.
Example: SSR 62-2, 1960-1974 Soc. Sec. Rep. Serv. 69 (Jan. 1, 1962).
For materials from the Surface Transportation Board, cite to the Surface Transportation
Board Reporter (S.T.B.). For materials from its predecessor, cite to the Interstate Commerce
Commission (ICC), to the Interstate Commerce Commission Reporter (I.C.C., I.C.C. 2d).
The official date for unpublished decisions is the date on which the decision was served on the
parties or otherwise filed by the STB (or ICC). Do not cite the date of the decision.
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H. TABLES
Alabama
Court of Civil Appeals (Ala. Civ. App.) and Court of Criminal Appeals (Ala. Crim.
App.), before 1969 Court of Appeals (Ala. Ct. App.): Cite to So., So. 2d, or So. 3d.
Administrative compilation
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Administrative register
Alaska
District Courts of Alaska (D. Alaska): These courts had local jurisdiction from 1884 to
1959. Cite to F. Supp., F., or F.2d; else, cite to Alaska or Alaska Fed., in that order of
preference.
United States District Courts for California and Oregon, and District Courts of
Washington (D. Cal., D. Or., D. Wash.): These courts had local jurisdiction in Alaska
until 1884. Cite to F. or F. Cas.
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H. TABLES
(West <year>)
Administrative compilation
Arizona
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Administrative compilation
Administrative register
Arkansas
128
H. TABLES
Administrative compilation
Local Notes:
Arkansas has adopted a public domain citation format for cases after February 13, 2009.
Citations include a parallel citation to the Southwestern Reports or other source. For
additional instruction, consult Arkansas Supreme Court Rule 5-2.
Examples:
Box v. J.B. Hunt Transp., Inc., 2017 Ark. App. 605, 533 S.W.3d 603.
Mounce v. Jeronimo Insulating LLC, 2021 Ark. App. 195, 2021 WL 1655901.
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California
Local Notes:
The year of cases is indicated parenthetically after the case name. Parallel citations may be
placed in brackets after the California Reports citation. Citation sentences are entirely enclosed
in parentheses.
Example: (Brescia v. Angelin (2009) 172 Cal.App.4th 133 [90 Cal.Rptr.3d 842]).
California statutory and administrative code citations follow state-specific abbreviations, such
as Cal. U. Com. Code for the California Uniform Commercial Code.
See Edward W. Jessen, California Style Manual: A Handbook of Legal Style for California
Courts and Lawyers (4th ed. 2000), available at http://www.sdap.org/downloads/Style-
Manual.pdf
Court of Appeal (Cal. Ct. App.), previously District Court of Appeal (Cal. Dist. Ct.
App.): Cite to P. or P.2d (before 1960) or Cal. Rptr., Cal. Rptr. 2d (after 1959), or Cal. Rptr.
3d.
Appellate Divisions of the Superior Court (Cal. App. Dep’t Super. Ct.): Cite to P. or
P.2d (before 1960) or to Cal. Rptr., Cal. Rptr. 2d (after 1959), or Cal. Rptr. 3d.
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H. TABLES
California Appellate Reports Supplement (bound with 1929–date Cal. App. Supp., Cal.
Cal. App.) App. 2d Supp., Cal. App.
3d Supp., Cal. App. 4th
Supp.
Statutory compilations: Cite to either the West or the Deering subject-matter code.
Civil Civ.
Commercial Com.
Corporations Corp.
Education Educ.
Elections Elec.
Evidence Evid.
Family Fam.
Financial Fin.
Government Gov’t
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Insurance Ins.
Labor Lab.
Penal Penal
Probate Prob.
Vehicle Veh.
Water Water
Administrative compilation
Administrative register
132
H. TABLES
Colorado
Supreme Court (Colo.): Cite to P., P.2d, or P.3d, if found there; else, cite to Colo., if found
there, or to Colo. Law. or Brief Times Rptr.
Court of Appeals (Colo. App.): Cite to P., P.2d, or P.3d, if found there; else, cite to Colo.
App., if found there, or else to one of the other reporters listed below.
1912–1915 P.
1891–1905 P.
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Administrative register
Local Notes:
Colorado has adopted a public domain citation format for cases after January 3, 2012. For
additional information, consult Rules of the Supreme Court of Colorado, Chief Justice
Directive 12-01.
Examples:
Connecticut
Supreme Court (Conn.), previously Supreme Court of Errors (Conn.): Cite to A.,
A.2d, or A.3d.
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H. TABLES
Superior Court (Conn. Super. Ct.) and Court of Common Pleas (Conn. C.P.): Cite
to A.2d or A.3d, if found there; else, cite to Conn. Supp., if found there, or else to one of the
other reporters listed below.
Session laws: Cite to Conn. Acts, Conn. Pub. Acts, or Conn. Spec. Acts.
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Connecticut Special Acts (Resolves & Private Laws, 1789–1971 <year> Conn. Spec. Acts
Private & Special Laws, Special Laws, Resolves & Private <page no.>
Acts, Resolutions & Private Acts, Private Acts &
Resolutions, and Special Acts & Resolutions)
Administrative compilation
Local Notes:
See generallyOffice of the Reporter of Judicial Decisions, The Manual of Style for the
Connecticut Courts (3d ed. 2013).
Delaware
Supreme Court (Del.), previously Court of Errors and Appeals (Del.): Cite to A.,
A.2d, or A.3d.
Delaware Reports
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H. TABLES
Superior Court (Del. Super. Ct.), previously Superior Court and Orphans’ Court
(Del. Super. Ct. & Orphans’ Ct.): Cite to A.2d or A.3d, if found there; else, cite to one of
the official reporters listed under Supreme Court (Del.).
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Local Notes:
The Delaware Code is cited as <vol.> Del. C. <section>. See generally Superior Court of
Delaware, Guide to the Delaware Rules of Legal Citation (2004), https://courts.delaware.gov
/superior/pdf/citation_guide.pdf
District of Columbia
Court of Appeals (D.C.), previously Municipal Court of Appeals (D.C.): Cite to A.2d
or A.3d.
United States Court of Appeals for the District of Columbia Circuit (D.C. Cir.),
previously Court of Appeals of/for the District of Columbia (D.C. Cir.), previously
Supreme Court of the District of Columbia (D.C.): Cite to F., F.2d, or F.3d.
138
H. TABLES
Hayward & Hazleton, Circuit Court (Circuit Court 1840–1863 <1–2> Hay. & Haz.
Reports, vols. 6–7)
Superior Court (D.C. Super. Ct.), previously Municipal Court (D.C. Mun. Ct.): Cite
to Daily Wash. L. Rptr.
West's District of Columbia Code Annotated (West) D.C. Code Ann. § x-x
(West <year>)
Session laws: Cite to Stat., D.C. Reg., or D.C. Code Adv. Leg. Serv.
139
The Indigo Book
Administrative register
Local Notes:
Florida
District Court of Appeal (Fla. Dist. Ct. App.): Cite to So. 2d or So. 3d.
Circuit Court (Fla. Cir. Ct.), County Court (e.g., Fla. Orange Cnty. Ct.), Public
Service Commission (Fla. P.S.C.), and other lower courts of record: Cite to Fla.
Supp. or Fla. Supp. 2d.
140
H. TABLES
Administrative compilation
Local Notes:
Florida statutes are customarily cited with section first: § xx.xxx, Fla. Stat. (2020).
At the intermediate appellate level, the Florida courts are divided into five District Courts of
Appeal. Citations indicate the applicable District Court of Appeal, abbreviated as DCA. See Fla.
R. App. P. 8.800; Indigo Book Rule R12.1.2.
Example: Saldana v. State, 295 So. 3d 1235 (Fla. 1st DCA 2020).
See generallyFlorida Style Manual (Florida State Univ. Law Rev., eds.,8th ed. 2019),
141
The Indigo Book
https://www.floridastylemanual.com/
Georgia
Administrative compilation
Official Compilation Rules and Regulations of the State of Ga. Comp. R. & Regs. x-
Georgia x-x.x (<year>)
Administrative register
142
H. TABLES
Local Notes:
The Official Code of Georgia Annotated is cited as O.C.G.A. See O.C.G.A. § 1-1-8(e).
Hawaii
Michie’s Hawaii Revised Statutes Annotated (LexisNexis) Haw. Rev. Stat. Ann. §
x-x (LexisNexis <year>)
143
The Indigo Book
Administrative compilation
Administrative register
Local Notes:
See generally A Handbook of Citation Forms for the Law Clerks at the Appellate Courts of the
State of Hawai’i (2008), https://www.law.hawaii.edu/sites/www.law.hawaii.edu/files/content
/library/HandbookofCitationForm.pdf (keyed to The Bluebook: A Uniform System of Citation
(Columbia L. Rev. et al., eds., 18th ed. 2005)).
Idaho
144
H. TABLES
Administrative register
Local Notes:
Illinois
Illinois Reports
145
The Indigo Book
Illinois Appellate Court Reports 1877–2011 Ill. App., Ill. App. 2d, Ill.
App. 3d
Illinois Circuit Court (Ill. Cir. Ct.), previously Court of Claims (Ill. Ct. Cl.): Cite to
Ill. Ct. Cl.
West’s Smith-Hurd Illinois Compiled Statutes Annotated <ch. no.> Ill. Comp.
Stat. Ann. <act no.> /
<sec. no.> (West
<year>)
146
H. TABLES
Administrative register
Local Notes:
Illinois has adopted a public domain citation format for cases effective July 1, 2011. See Illinois
Supreme Court Rule 6. Thus, when citing an Illinois intermediate appellate court decision and
including a parallel citation to the North Eastern Reporter, it is advisable to include the
intermediate appellate division, noting also that the public domain format renders the court
and year unambiguously clear. See generallyStyle Manual for the Supreme Court and
Appellate Courts of Illinois (5th ed. 2017), https://courts.illinois.gov/StyleManual/SupCrt
_StyleManual.pdf
Examples:
Archer Daniels Midland Co. v. Sinele, 2019 IL App (4th) 180714, 139 N.E.3d 1036.
Indiana
147
The Indigo Book
Court of Appeals (Ind. Ct. App.), previously Appellate Court (Ind. App.): Cite to
N.E., N.E.2d, or N.E.3d.
Indiana Court of Appeals Reports (prior to 1972, Indiana 1890–1979 Ind. App.
Appellate Court Reports)
148
H. TABLES
Administrative register
Local Notes:
The Indiana Code is referred to in short citations as I.C. or IC. The Indiana Administrative
Code is referred to in short citations as I.A.C. or IAC. See Ind. R. App. P. 22 (2021),
https://www.in.gov/courts/rules/appellate/index.html.
Iowa
Iowa Reports (Cite to edition published by Clarke for vols. 1855–1968 Iowa
1–8.)
149
The Indigo Book
Administrative compilation
Administrative register
Kansas
150
H. TABLES
Administrative compilation
Administrative register
Local Notes:
Kansas Statutes Annotated are cited as K.S.A. xx-xxx. SeeKansas Appellate Practice
Handbook, Citation Guide app’x C (2018), https://www.kansasjudicialcouncil.org/
Documents/Appellate%20Practice%20Handbook/Appendix%20C-Revised%202018.pdf
Kentucky
Supreme Court (Ky.): before 1976 the Court of Appeals (Ky.) was the highest state court.
Cite to S.W., S.W.2d, or S.W.3d.
Kentucky Reports
151
The Indigo Book
Court of Appeals (Ky. Ct. App.) (for decisions before 1976, see Kentucky Supreme
Court): Cite to S.W.2d or S.W.3d.
Baldwin’s Kentucky Revised Statutes Annotated (West) Ky. Rev. Stat. Ann. § x.x
(West <year>)
Michie’s Kentucky Revised Statutes Annotated Ky. Rev. Stat. Ann. § x.x
(LexisNexis) (LexisNexis <year>)
Kentucky Revised Statutes and Rules Service (West) <year> Ky. Rev. Stat. &
R. Serv. <page no.>
152
H. TABLES
(West)
Administrative compilation
Administrative register
Local Notes:
The Kentucky Revised Statutes Annotated are cited locally as KRS xx.xxxx. See Ky. R. Civ. P.
76.12(4)(g).
Louisiana
Supreme Court (La.), before 1813 the Superior Court of Louisiana (La.) and the
Superior Court of the Territory of Orleans (Orleans): Cite to So., So. 2d, or So. 3d.
Court of Appeal (La. Ct. App.): Cite to So., So. 2d, or So. 3d.
153
The Indigo Book
West’s Louisiana Children’s Code Annotated La. Child. Code Ann. art.
x (<year>)
West’s Louisiana Civil Code Annotated La. Civ. Code Ann. art. x
(<year>)
West’s Louisiana Code of Civil Procedure Annotated La. Code Civ. Proc. Ann.
art. x (<year>)
West’s Louisiana Code of Criminal Procedure Annotated La. Code Crim. Proc.
Ann. art. x (<year>)
West’s Louisiana Code of Evidence Annotated La. Code Evid. Ann. art.
x (<year>)
State of Louisiana: Acts of the Legislature <year> La. Acts <page no.>
Administrative compilation
Administrative register
154
H. TABLES
Local Notes:
Local practice in Louisiana uses large-and-small caps for statutes: LA. CIV. CODE art. 2315
(2019). For administrative rules, likewise local practice uses large-and-small caps: LA. ADMIN.
CODE tit. 51, pt. 1, §105 (2019). See generally Louisiana Citation and Style Manual, 70 La. L.
Rev. 1239 (2019), https://digitalcommons.law.lsu.edu/lalrev/vol79/iss4/13/
Louisiana has adopted a public domain citation format for cases after December 31, 1993. See
Rules of the Supreme Court of Louisiana, part G, section 8. The format is:
Examples:
Smith v. Jones, 93-2345 (La. App. 1 Cir. 7/15/94); 660 So.2d 400.
Maine
Maine Revised Statutes Annotated (West) Me. Rev. Stat. Ann. tit.
x, § x (<year>)
155
The Indigo Book
Administrative compilation
Administrative register
Local Notes:
Maine has adopted a public domain citation format for cases after December 31, 1996. See
Administrative Order of the Supreme Judicial Court—New Citation Form (Aug. 20, 1996);
Michael D. Selzinger, Charles K. Leadbetter, and Sara T.S. Wolfe, Uniform Maine Citations
(2020-21 ed.), https://digitalcommons.mainelaw.maine.edu/uniform-maine-citations/16/
Examples:
Maryland
156
H. TABLES
Court of Special Appeals (Md. Ct. Spec. App.): Cite to A.2d or A.3d.
Statutory compilations: Cite by subject to either Michie’s Md. Code Ann. or West’s Md.
Code Ann.
Agriculture Agric.
Constitutions Const.
Education Educ.
Environment Envir.
157
The Indigo Book
Health–General Health–Gen.
Insurance Ins.
Tax–General Tax–Gen.
Tax–Property Tax–Prop.
Transportation Transp.
158
H. TABLES
Administrative compilation
Administrative register
Massachusetts
Massachusetts Reports
Lower Courts (Mass. Dist. Ct., Bos. Mun. Ct.): Cite to Mass. App. Div., if found there;
else cite to Mass. Supp. or Mass. App. Dec.
159
The Indigo Book
General Laws of Massachusetts (Mass. Bar Ass’n/West): Mass. Gen. Laws ch. x, §
x (<year>)
Mass. Gen. Laws ch.<chapter no.>, § <section no.>
(<year> )
160
H. TABLES
(LexisNexis <year>)
Administrative register
Local Notes:
Michigan
161
The Indigo Book
Public and Local Acts of the Legislature of the State of <year> Mich. Pub. Acts
Michigan <page no.>
Administrative compilation
Administrative register
Local Notes:
The Michigan Compiled Laws are customarily cited locally as MCL xxxx.xx. See Michigan
Supreme Court Office of the Reporter of Decisions, Michigan Appellate Opinion Manual (rev.
Dec. 2017), https://courts.michigan.gov/Courts/MichiganSupremeCourt/Documents
/MiAppOpManual.pdf
Minnesota
162
H. TABLES
Administrative compilation
Administrative register
Mississippi
Mississippi Reports
163
The Indigo Book
Administrative compilation
Administrative register
Local Notes:
Mississippi has adopted a public domain citation format for cases after July 1, 1997. See Miss.
R. App. P. 28(f), https://courts.ms.gov/research/rules/msrulesofcourt
/Rules%20of%20Appellate%20Procedure%20Current.pdf.
Examples:
164
H. TABLES
Missouri
Administrative compilation
Missouri Code of State Regulations Annotated Mo. Code Regs. Ann. tit.
x, § x-x.x (<year>)
Administrative register
Local Notes:
Missouri statutes are cited locally around the following basic template: Section xxx.xxx, RSMo
2016 or § xxx.xxx, RSMo 2016. Missouri Supreme Court cases are generally decided en banc
165
The Indigo Book
and are cited (Mo. banc <year>). The Missouri Court of Appeals is cited locally as “Mo. App.”
(omitting the “Ct.” as shown in this Table). Missouri Court of Appeals cases may indicate the
district of decision where relevant: (Mo. App. S.D.). See Thomas Patrick Deaton, Jr., Show Me
Citations: A Manual for Legal Citations in Missouri Courts (9th ed. 2020) (practitioner-
maintained manual), https://www.thomaspatrickdeaton.com/ShowMeCitations2020
-0706.pdf
Montana
Session laws
Administrative compilation
Administrative register
Local Notes:
Montana has adopted a public domain citation format for cases after December 31, 1997. See
Order In re: Opinion Forms and Citation Standards of the Supreme Court of Montana and the
166
H. TABLES
Adoption of Public Domain and Neutral-Format Citation (Dec. 16, 1997); Order In the Matter
of Aneding Citation Standards, No. AF-07-0064 (Jan. 22, 2009); Order in the Matter of
Amending Citations Standards for the Montana Supreme Court, No. AF 06-0632 (Feb. 24,
2010), https://casetext.com/case/in-re-matter-of-opinion-forms.
Example: Doe v. Roe, 1998 MT 12, ¶¶ 44-45, 286 Mont. 175, 989 P.2d 1312.
Nebraska
Administrative compilation
Nevada
167
The Indigo Book
Michie's Nevada Revised Statutes Annotated (LexisNexis) Nev. Rev. Stat. Ann. §
x.x (LexisNexis <year>)
Administrative compilation
Administrative register
New Hampshire
New Hampshire Revised Statutes Annotated (West) N.H. Rev. Stat. Ann. §
168
H. TABLES
x:x (<year>)
Lexis New Hampshire Revised Statutes Annotated N.H. Rev. Stat. Ann. §
x:x (LexisNexis <year>)
New Jersey
169
The Indigo Book
Supreme Court (N.J.), previously Court of Errors and Appeals (N.J.): Cite to A.,
A.2d, or A.3d.
Superior Court (N.J. Super. Ct. App. Div., N.J. Super. Ct. Ch. Div., N.J. Super. Ct.
Law Div.), previously Court of Chancery (N.J. Ch.), Supreme Court (N.J. Sup.
Ct.), and Prerogative Court (N.J. Prerog. Ct.): Cite to A., A.2d, or A.3d.
County Court (e.g., Essex Cnty. Ct.) and other lower courts: Cite to A.2d.
New Jersey Session Law Service (West) <year> N.J. Sess. Law
170
H. TABLES
Administrative compilation
Administrative register
Administrative report
Local Notes:
In local practice, the New Jersey Constitution’s name is underlined: N.J. Const. art. <Roman
numeral>, § <number>, ¶ <number>. New Jersey Statutes Annotated are cited as N.J.S.A.
followed by the relevant section number but no section symbol: N.J.S.A. <section number>.
See New Jersey Manual on Style for Judicial Opinions (2017), https://www.njcourts.gov
/attorneys/assets/attyresources/manualonstyle.pdf
New Mexico
New Mexico Statutes Annotated 1978 (Conway Greene) N.M. Stat. Ann. § x-x-x
(<year>)
171
The Indigo Book
(West <year>)
Michie's Annotated Statutes of New Mexico (LexisNexis) N.M. Stat. Ann. § x-x-x
(LexisNexis <year>)
New Mexico Advance Legislative Service (Conway <year> N.M. Adv. Legis.
Greene) Serv. <page no.>
Administrative compilation
Administrative register
Local Notes:
New Mexico has adopted a public domain citation format for cases effective July 1, 2013. See
N.M. Sup. Ct. R. 23-112 (Appendix), available at https://casetext.com/rule/new-mexico-court
-rules/new-mexico-supreme-court-general-rules/rule-23-112-citations-for-pleadings-and
-other-papers/appendix-to-rule-23-112-nmra-technical-and-citation-information.
Examples:
New York
172
H. TABLES
New York Reports (The first series of N.Y. is reprinted in 1847–date N.Y., N.Y.2d
N.Y.S. and N.Y.S.2d without separate pagination. Do not
include a parallel cite to N.Y.S. or N.Y.S.2d in citations to
the first series of N.Y.)
Court for the Correction of Errors (N.Y.) and Supreme Court of Judicature (N.Y.
Sup. Ct.) (highest state courts of law before 1847): Cite to one of the following
reporters.
Court of Chancery (N.Y. Ch.) (highest state court of equity before 1848): Cite to one
of the following reporters.
173
The Indigo Book
Supreme Court, Appellate Division (N.Y. App. Div.), previously Supreme Court,
General Term (N.Y. Gen. Term): Cite to N.Y.S., N.Y.S.2d, or N.Y.S.3d.
Other lower courts (e.g., N.Y. App. Term, N.Y. Sup. Ct., N.Y. Ct. Cl., N.Y. Civ. Ct.,
N.Y. Crim. Ct., N.Y. Fam. Ct.): Cite to N.Y.S., N.Y.S.2d, or N.Y.S.3d.
Other lower courts before 1888: Cite to one of the following reporters.
174
H. TABLES
Banking Banking
Canal Canal
Commerce Com.
175
The Indigo Book
Correction Correct.
County County
Education Educ.
Elder Elder
Election Elec.
Energy Energy
Executive Exec.
Highway High.
Indian Indian
Insurance Ins.
176
H. TABLES
Judiciary Jud.
Labor Lab.
Legislative Legis.
Lien Lien
Military Mil.
Municipal Home Rule and Statute of Local Governments Mun. Home Rule
Navigation Nav.
Partnership P’ship
Penal Penal
177
The Indigo Book
Railroad R.R.
State State
State Printing and Public Documents State Print. & Pub. Docs.
Statutes Stat.
Tax Tax
Town Town
Transportation Transp.
178
H. TABLES
Unconsolidated Unconsol.
Village Village
Uncompiled laws: Cite to one of the following sources. For the user’s convenience, the
McKinney’s volume in which the law appears is indicated parenthetically below.
New York City Civil Court Act (29A) City Civ. Ct. Act
New York City Criminal Court Act (29A) City Crim. Ct. Act
Session laws: Cite to official N.Y. Laws, if found there; else, cite to N.Y. Sess. Laws.
179
The Indigo Book
no.>
McKinney's Session Laws of New York (West) <year> N.Y. Sess. Laws
(McKinney) <page no.>
Administrative compilation
Official Compilation of Codes, Rules & Regulations of the N.Y. Comp. Codes R. &
State of New York (West) Regs. tit. x, § x (<year>)
Administrative register
Local Notes:
Case-citation formats follow the formats shown in the New York Law Reports Style Manual
(2017 ed., with cumulative updates through 2020), https://www.nycourts.gov/reporter/style
-manual/2017/2017-SM.htm. A few key differences include citing the applicable reporter from
the New York Official Reports Service, and indicating the Department of the Appellate Division
in the court/year parenthetical for intermediate appellate divisions. A few formatting
differences include placing the entire citation in parentheses, placing the year in brackets, and
omitting periods from the various citation components.
Examples:
(Boss v Am. Express Fin. Advisors, Inc., 15 AD3d 306 [1st Dept 2005]).
Statutory citations also vary significantly from the Uniform System of Citation’s general
standards. For example, periods with abbreviations are also often omitted from New York
statutory citations in local practice, such as with citing the Civil Practice Laws and Rules are as
CPLR xxxx.
North Carolina
180
H. TABLES
Devereux & Battle’s Equity (21–22) 1834–1839 e.g., 21 N.C. (1 Dev. &
Bat. Eq.)
Devereux & Battle’s Law (18–20) 1834–1839 e.g., 20 N.C. (3 & 4 Dev.
& Bat.)
181
The Indigo Book
West’s North Carolina General Statutes Annotated N.C. Gen. Stat. Ann. § x-
x (West <year>)
Administrative compilation
Administrative register
Local Notes:
182
H. TABLES
North Carolina has adopted a public domain citation format, effective January 2021. See
Supreme Court of North Carolina, Universal Citation for North Carolina Fact Sheet (Nov.
2020), https://www.nccourts.gov/assets/news-uploads/FINAL_fact-sheet_UniversalCitation-
-SCofNC_11182020.pdf?JVPiE5JQ6Yeng5IJ8_a1TzZF6bjdSTgt
Examples:
North Carolina statutes are cited as N.C.G.S. § xx-xx (year). See generally Supreme Court
Office of Administrative Counsel, The Guidebook: Citation, Style, and Usage at the Supreme
Court of North Carolina (2019), https://www.nccourts.gov/assets/inline-files/TheGuidebook
_SupremeCourtofNorthCarolina_062019_0.pdf?1lTTY94loM9lL3LuzuIEZ04IbNaxjiSJ;
Appellate Rules Committee of the North Carolina Bar Association, A Style Manual for the
North Carolina Rules of Appellate Procedure (2021), https://www.ncbar.org/wp-content
/uploads/2021/05/2021-05-13-FINAL-Style-Manual-with-Hyperlinks.pdf.
North Dakota
West’s North Dakota Century Code Annotated N.D. Cent. Code Ann. §
x-x-x (West <year>)
183
The Indigo Book
Administrative compilation
Local Notes:
North Dakota has adopted a public domain citation format for cases after December 31, 1996.
See North Dakota Supreme Court Citation Manual (2000), https://www.ndcourts.gov/
supreme-court/citation-manual
Examples:
Ohio
184
H. TABLES
Other law courts: Cite to N.E., N.E.2d, or N.E.3d, if found there; else, cite to another
reporter in the following order of preference.
Ohio Circuit Court Reports, New Series 1903–1917 Ohio C.C. (n.s.)
185
The Indigo Book
Page’s Ohio Revised Code Annotated (LexisNexis): Ohio Rev. Code Ann. §
x.x (LexisNexis <year>)
Ohio Rev. Code Ann. § <section number> (LexisNexis
<year> )
Baldwin’s Ohio Revised Code Annotated (West): Ohio Rev. Code Ann. §
x.x (West <year>)
Ohio Rev. Code Ann. § <section number> (West <year>
)
State of Ohio: Legislative Acts Passed and Joint Resolutions Adopted <year> Ohio Laws
<page no.>
Baldwin’s Ohio Legislative Service Annotated (West) <year> Ohio Legis. Serv.
Ann. <page no.> (West)
Administrative compilation
186
H. TABLES
Local Notes:
Extensive guidance and rules are provided by the Supreme Court of Ohio’s Writing Manual: A
Guide to Citations, Style, and Judicial Opinion Writing (2d ed. 2013),
https://www.supremecourt.ohio.gov/ROD/manual.pdf.
The Ohio Revised Code is customarily cited locally as R.C. § xx.xx. A common local variation of
this statutory citation is O.R.C. § xx.xx.The Ohio Court of Appeals is divided into appellate
districts that should be indicated parenthetically in the court/year component. Ohio has
adopted a public domain citation format for cases decided after April 30, 2002.
Examples:
Bonacorsi v. Wheeling & Lake Erie Ry. Co., 95 Ohio St.3d 314, 2002-Ohio-2220, 767
N.E.2d 707, ¶ 15.
Bowling Green v. Godwin, 110 Ohio St.3d 58, 2006-Ohio-3563, 850 N.E.2d 698, ¶ 13,
fn. 1.
Byer v. Wright, 160 Ohio App.3d 472, 2005-Ohio-1797, 827 N.E.2d 835 (11th Dist.).
Oklahoma
Court of Criminal Appeals (Okla. Crim. App.), before 1959 Criminal Court of
Appeals (Okla. Crim. App.): Cite to P., P.2d, or P.3d.
187
The Indigo Book
Administrative compilation
Local Notes:
Oklahoma has adopted a public domain citation format for cases after May 1, 1997. See Okla.
Sup. Ct. R. 1.200(e); Okla. Crim. App. R. 3.5.C(2)(a).
Examples:
MTG Guarnieri Mfg., Inc. v. Clouatre, 2010 OK CIV APP 71, 239 P.3d 202.
Harvell v. Goodyear Tire & Rubber Co., 2006 OK 24, 164 P.3d 1028.
Oregon
188
H. TABLES
West’s Oregon Revised Statutes Annotated Or. Rev. Stat. Ann. § x.x
(West <year>)
Session laws: Cite to Or. Laws. When citing statutes repealed during or after 1953, indicate
parenthetically the former Or. Rev. Stat. sections.
Administrative compilation
Administrative register
189
The Indigo Book
day, year>)
Local Notes:
Pennsylvania
190
H. TABLES
For cases decided after December 31, 1998, use the following public domain citation format:
Example:
Other lower courts: Cite to Pa. D. & C., Pa. D. & C.2d, Pa. D. & C.3d, Pa. D. & C.4th, or Pa.
D. & C.5th. Not all lower court decisions are reproduced in the reporters listed below, and it
may be necessary, on occasion, to cite to the legal reporter for an individual county, if
available. For a comprehensive list of Pennsylvania county court reports, consult chapter
seven, appendix four, Frank Y. Liu et al., Pennsylvania Legal Research Handbook (2008).
Pennsylvania District and County Reports 1918–date Pa. D. & C., Pa. D. &
C.2d, Pa. D. & C.3d, Pa.
D. & C.4th, Pa. D. &
C.5th
Statutory compilations: Cite to Pa. Cons. Stat. (79 titles). These publications should not be
confused with Pa. Code, which is a code of regulations, not of legislation.
Purdon’s Pennsylvania Statutes and Consolidated <tit. no.> Pa. Stat. and
Statutes Annotated (West) Cons. Stat. Ann. § x
(West <year>)
191
The Indigo Book
no.>
Administrative compilation
Administrative register
Local Notes:
Pennsylvania has a complex system of consolidated and unconsolidated statutes, and may
provide a parallel citation to Purdom’s Pennsylvania Statutes Annotated if available. See
Order Amending Rule 126 of the Pennsylvania Rules of Appellate Procedure, No. 278
Appellate Procedural Rules Doc., 49 Pa. B. 1335 (March 23, 2019),
http://www.pacodeandbulletin.gov/Display/pabull?file=/secure/pabulletin/data/vol49/49-12
/416.html.
Rhode Island
General Laws of Rhode Island (LexisNexis) <tit. no.> R.I. Gen. Laws
§ x-x-x (<year>)
West’s General Laws of Rhode Island Annotated <tit. no.> R.I. Gen. Laws
Ann. § x-x-x (West
<year>)
Public Laws of Rhode Island and Providence Plantations <year> R.I. Pub. Laws
192
H. TABLES
<page no.>
Acts and Resolves of Rhode Island and Providence <year> R.I. Acts &
Plantations Resolves <page no.>
West’s Rhode Island Advance Legislative Service <year> R.I. Adv. Legis.
Serv. <page no.> (West)
Administrative compilation
Administrative register
South Carolina
Courts of law before 1868: Cite to South Carolina Law Reports (S.C.L.)
193
The Indigo Book
Courts of equity before 1868: Cite to South Carolina Equity Reports (S.C. Eq.)
194
H. TABLES
Statutory compilation
Code of Laws of South Carolina 1976 Annotated S.C. Code Ann. § x-x-x
(<year>)
Session laws
Acts and Joint Resolutions, South Carolina <year> S.C. Acts <page
no.>
Code of Laws of South Carolina 1976 Annotated: Code of S.C. Code Ann. Regs.
Regulations (West) <reg no.> (<year>)
Administrative register
195
The Indigo Book
South Dakota
Statutory compilation
Administrative compilation
Administrative register
Local Notes:
The South Dakota Codified Laws are locally cited as SDCL § x-x-x. See SDCL § 2-16-18.
South Dakota has adopted a public domain citation format for cases after December 31, 1996.
See S.D. R. Civ. Pro. § 15-26A-69.1 and S.D. Sup. Ct. R. 10-05.
Example:
JAS Enters., Inc. v. BBS Enters., Inc., 2013 S.D. 54, 835 N.W.2d 117.
196
H. TABLES
Tennessee
Tennessee Reports
197
The Indigo Book
Administrative compilation
Official Compilation Rules & Regulations of the State of Tenn. Comp. R. & Regs.
Tennessee <rule no.> (<year>)
Administrative register
Texas
Synopses of the Decisions of the Supreme Court of Texas 1862–1865 Robards (no vol.
Arising from Restraints by Conscript and Other Military number)
Authorities (Robards)
198
H. TABLES
Digest of the Laws of Texas (Dallam’s Opinions) 1840–1844 Dallam (no vol.
number)
Court of Criminal Appeals (Tex. Crim. App.), previously Court of Appeals (Tex.
Ct. App.): Cite to S.W., S.W.2d, or S.W.3d.
Condensed Reports of Decisions in Civil Causes in the 1876–1883 White & W. Willson
Court of Appeals (White & Willson vol. 1) (Willson vols. 1883–1892
2–4)
1918–1945 S.W.2d
Courts of Appeals (Tex. App.), previously Courts of Civil Appeals (Tex. Civ. App.):
Cite to S.W., S.W.2d, or S.W.3d.
Consult Texas-specific citation guides for historical subsequent history when citing opinions of
the Commission of Appeals from 1879 to 1892. For additional information on the history and
structure of Texas courts and on local citation rules, the following sources are suggested: Texas
Law Review Ass’n, The Greenbook: Texas Rules of Form (14th ed. 2018); Lydia M.V. Brandt,
199
The Indigo Book
Texas Legal Research (1995); and A Reference Guide to Texas Law and Legal History (Karl T.
Gruben & James E. Hambleton eds., 2d ed. 1987).
Statutory compilations: Texas is nearing the completion of a recodification of its laws. Cite
to the new subject-matter Tex. Code Ann., if found there; else, cite to Tex. Rev. Civ. Stat. Ann.
or to one of the independent codes contained in the series Vernon’s Texas Civil Statutes or
Vernon’s Texas Statutes Annotated. Note that the independent codes are not part of the new
subject-matter Tex. Code Ann.
Vernon’s Texas Revised Civil Statutes Annotated (West) Tex. Rev. Civ. Stat. Ann.
art. x, § x (West <year>)
Vernon’s Texas Business Corporation Act Annotated Tex. Bus. Corp. Act Ann.
(West) art. x (West <year>)
Vernon’s Texas Code of Criminal Procedure Annotated Tex. Code Crim. Proc.
(West) Ann. art. x (West
<year>)
Vernon’s Texas Insurance Code Annotated (West) Tex. Ins. Code Ann. art.
x (West <year>)
Vernon’s Texas Probate Code Annotated (West) Tex. Prob. Code Ann. § x
(repealed) (West <year>)
Agriculture Agric.
200
H. TABLES
Education Educ.
Election Elec.
Estates Est.
Family Fam.
Finance Fin.
Government Gov’t
Insurance Ins.
Labor Lab.
Occupations Occ.
Penal Penal
Property Prop.
Tax Tax
Transportation Transp.
Utilities Util.
Water Water
General and Special Laws of the State of Texas <year> Tex. Gen. Laws
<page no.>
Vernon’s Texas Session Law Service (West) <year> Tex. Sess. Law
Serv. <page no.> (West)
201
The Indigo Book
Session laws passed before 1941 must be cited according to the exact title, e.g., Tex. Loc. &
Spec. Laws, Tex. Gen. & Spec. Laws, and Tex. Gen. Laws. The Revised Statutes were enacted
and published separately in 1879, 1895, 1911, and 1925 and should be cited as <year> Tex. Rev.
Civ. Stat. xxx. The Code of Criminal Procedure and Penal Code were enacted and published
separately in 1856, 1879, 1895, 1911, and 1925 and should be cited as <year> Tex. Crim. Stat.
xxx.
Administrative compilation
Administrative register
Local Notes:
See generally The Greenbook, Texas Rules of Form (14th ed. 2018).At the intermediate
appellate level, the Texas courts are divided into regional intermediate appellate districts.
Customary local practice for Texas intermediate appellate citations is as follows: <case
name>, <vo.> S.W. 2d <page> (Tex. App.—<name of intermediate appellate district> <year>).
The Houston appellate district has two numbered districts and thus also includes either [1st
Dist.] or [14th Dist.]. Customary local practice also includes subsequent history in the citation
parenthetical. See The Greenbook: Texas Rules of Form (14th 2018).
Example:
Titan Oil & Gas Consultants, LLC v. Willis, 614 S.W.3d 261 (Tex. App.—Texarkana 2020, pet.
filed).
Utah
202
H. TABLES
Administrative compilation
Administrative register
Local Notes:
Utah has adopted a public domain citation format for cases after December 31, 1998. See Utah
App R. 24(f). Include parallel citations to the Pacific Reporter where available.
Include parallel citations to the Utah Advanced Reports (if possible) when no citation to the
Pacific Reporter is available.
203
The Indigo Book
Examples:
Smith v. Jones, 1999 UT App 16, 380 Utah Adv. Rep. 24.
Vermont
Statutory compilations: Cite to Vt. Stat. Ann. (published by LexisNexis), if found there
204
H. TABLES
Administrative compilation
Administrative register
Local Notes:
Vermont Statutes Annotated are cited locally as xx V.S.A. § xx. See 1 V.S.A. § 51.
Vermont has adopted a public domain citation format for cases after December 31, 2002. See
Vt. R. App. P. 28.2.
Example: Smith v. Jones, 2001 VT 1, ¶ 12, 169 Vt. 203, 850 A.2d 421.
Virginia
Supreme Court (Va.), previously Supreme Court of Appeals (Va.): Cite to S.E. or
S.E.2d.
Virginia Reports
205
The Indigo Book
Acts of the General Assembly of the Commonwealth of <year> Va. Acts <page
Virginia no.>
Administrative compilation
Administrative register
206
H. TABLES
Washington
Administrative compilation
Administrative register
207
The Indigo Book
Local Notes:
Locally, the state code is often cited RCW xx.xx.xx. See generally Official Reporter of
Decisions, Style Sheet, Washington Courts (July 3, 2018), https://www.courts.wa.gov
/appellate_trial_courts/supreme/?fa=atc_supreme.style.
West Virginia
Michie’s West Virginia Code Annotated (LexisNexis) W. Va. Code Ann. § x-x-
x (LexisNexis <year>)
208
H. TABLES
Administrative compilation
Administrative register
Wisconsin
Burnett (bound with session laws for Dec. 1841) 1841 Bur.
209
The Indigo Book
Administrative compilation
Administrative register
Local Notes:
Wisconsin has adopted a public domain citation format for cases decided after December 31,
1999. See Wis. Sup. Ct. R. 80, https://www.wicourts.gov/sc/scrule/DisplayDocument.pdf
?content=pdf&seqNo=146082.
Examples:
Wyoming
210
H. TABLES
Administrative compilation
Administrative register
Local Notes:
Wyoming has adopted a public domain citation format for cases decided after December 31,
2003. See Order Amending Citation Format (Aug. 19, 2005). Parallel citations are optional.
Examples:
American Samoa
High Court of American Samoa (Am. Samoa): Cite to Am. Samoa, Am. Samoa 2d, or
Am. Samoa 3d.
Statutory compilation
211
The Indigo Book
Administrative compilation
Canal Zone
United States District Court for the Eastern District of Louisiana (E.D. La.): This
court has jurisdiction over litigation pending as of Apr. 1, 1982, in the United States District
Court for the District of the Canal Zone. Cite to F. Supp.
United States District Court for the District of the Canal Zone (D.C.Z.): This court
ceased to exist on Mar. 31, 1982. Cite to F. Supp.
Statutory compilation
Guam
The Supreme Court of Guam uses a public domain format as shown here. A parallel citation
may be included.
Example:
District Court of Guam (D. Guam): Cite to F. Supp., F. Supp. 2d, or F. Supp. 3d.
Statutory compilation
212
H. TABLES
Session laws
Administrative compilation
Administrative Rules & Regulations of the Government of <tit. no.> Guam Admin.
Guam R. & Regs. § x (<year>)
Navajo Nation
Supreme Court (Navajo), previously Court of Appeals (Navajo): Cite to Navajo Rptr.
Statutory compilation
The Commonwealth of the Northern Mariana Islands has adopted a public domain citation
format.
Example:
See Northern Mariana Islands Supreme Court Style Manual (Jan. 1, 2017), http://cnmilaw.org
/pdf/courtrules/R26.pdf.
District Court for the Northern Mariana Islands, Trial and Appellate Divisions
(D. N. Mar. I. and D. N. Mar. I. App. Div.), and Commonwealth Superior Court (N.
213
The Indigo Book
Mar. I. Commw. Super. Ct.), previously Commonwealth Trial Court (N. Mar. I.
Commw. Trial Ct.): Cite to F. Supp., F. Supp. 2d, or F. Supp. 3d.
Statutory compilation
Session laws
Administrative compilation
Administrative register
Puerto Rico
Puerto Rico has adopted a public domain citation format for cases decided after December 31,
1997. The format is:
Example: Yumac Home Furniture v. Caguas Lumber Yard, 2015 TSPR 148.
214
H. TABLES
Supreme Court (P.R.): Cite to P.R. or P.R. Offic. Trans., if found there; else, cite to P.R.
Dec. or P.R. Sent., in that order of preference.
Official Translations of the Opinions of the Supreme 1978–date P.R. Offic. Trans.
Court of Puerto Rico
Statutory compilation
Session laws
Virgin Islands
Statutory compilation
Virgin Islands Code Annotated (LexisNexis) 1962–date V.I. Code Ann. tit. x, § x-
x <year>
215
The Indigo Book
<page no.>
Administrative compilation
Code of U.S. Virgin Islands Rules (LexisNexis) <tit. no.>-<ch. no.> V.I.
Code R. § x-x
(LexisNexis <year>)
Administrative register
Bloomberg Law BL
Matthew Bender MB
216
H. TABLES
Affirmative Action Compliance Manual for Federal Contractors Aff. Action Compl. Man.
(BL)
217
The Indigo Book
218
H. TABLES
Federal Estate and Gift Tax Reporter Fed. Est. & Gift Tax Rep.
219
The Indigo Book
(CCH)
Federal Income, Gift and Estate Taxation Fed. Inc. Gift & Est. Tax’n
(MB)
Government Employee Relations Report (ceased publication Gov’t Empl. Rel. Rep.
November 2017) (BL)
⇒ bound as Life, Health & Accident Insurance Cases 2d Life Health & Accid. Ins.
Cas. 2d (CCH)
220
H. TABLES
⇒ bound as Wage and Hour Cases Wage & Hour Cas. (BL)
National Reporter on Legal Ethics & Professional Responsibility Nat’l Rep. Legal Ethics
(Univ. Pub. Am.)
221
The Indigo Book
Product Safety & Liability Reporter Prod. Safety & Liab. Rep.
(BL)
Securities and Federal Corporate Law Report Sec. & Fed. Corp. L. Rep.
(West)
Securities Regulation & Law Report Sec. Reg. & L. Rep. (BL)
222
H. TABLES
State and Local Tax Service St. & Loc. Tax Serv. (RIA)
State Inheritance, Estate, and Gift Tax Reporter St. Inher., Est. & Gift Tax
Rep. (CCH)
Uniform Commercial Code Reporting Service Second UCC Rep. Serv. (West)
The United States Law Week (published by Bloomberg Law, which U.S.L.W.
need not be indicated in the service citation)
The United States Patents Quarterly bound in same name U.S.P.Q. (BL),
U.S.P.Q.2d (BL)
U.S. Tax Cases—see Federal Estate and Gift Tax Reporter and
Standard Federal Tax Reporter
223
The Indigo Book
Annals Annals
Annual Ann.
Bill B.
Committee Comm.
Concurrent Con.
Conference Conf.
Congress[ional] Cong.
Debate Deb.
Delegate Del.
Document[s] Doc.
Executive Exec.
Federal Fed.
House H.
224
H. TABLES
Joint J.
Legislature Leg.
Miscellaneous Misc.
Number No.
Order Order
Record Rec.
Register Reg.
Regular Reg.
Report Rep.
Representative Rep.
Resolution Res.
Senate S.
Senator Sen.
Service Serv.
Session Sess.
Special Spec.
Subcommittee Subcomm.
225
The Indigo Book
226
H. TABLES
Commission Comm’n
Court Ct.
227
The Indigo Book
Division Div.
228
H. TABLES
229
The Indigo Book
Tribunal Trib.
Arbitrator Arb.
230
H. TABLES
Title Abbreviation
Baron B.
Chancellor C.
Commissioner Comm’r
Delegate Del.
Honorable Hon.
Judge, Justice J.
Magistrate Mag.
Mediator Med.
Referee Ref.
Representative Rep.
Senator Sen.
231
The Indigo Book
Using the common-word abbreviations in this table, here are examples of each:
In case names and periodical titles, words can be pluralized by adding “s” to the abbreviation
(Dep’ts, Exchs.) Possessive words are indicated with ’s after the abbreviation when singular
(Mfr.’s ) and with ’ after the abbreviation when plural (Mfrs.’). Other words of eight letters or
more may be abbreviated to save significant space, if the abbreviation is clear.
In case names, well-known acronyms can be abbreviated as such per Rule 11.2.19.
Abbreviations already in periodical titles should be maintained as such (whether well-known or
not) such as “NALP Bulletin” (which is the title of that publication).
In periodical titles, omit the words “a,” “at,” “in,” “of,” and “the.” If a title contains a single
word after one of these short omitted words, do not abbreviate the next word. For example,
“Journal of Construction” would become “J. Construction” (despite the abbreviation “Const.”
in this table.) Omit words after a colon in a periodical title. Periodical titles have additional
institution-specific and geographical abbreviations shown in Table T12 and T15.
Advertising Advert.
Affair Aff.
Alliance All.
Alternative Alt.
232
H. TABLES
Amendment Amend.
and &
Annual Ann.
Appellate App.
Associate Assoc.
Association Ass’n
Atlantic Atl.
Attorney Att’y
Authority Auth.
Avenue Ave.
Bankruptcy Bankr.
Board Bd.
Brotherhood Bhd.
Brothers Bros.
Building Bldg.
Capital Cap.
Catholic Cath.
233
The Indigo Book
Central Cent.
Chemical Chem.
Children Child.
Chronicle Chron.
Circuit Cir.
Coalition Coal.
College Coll.
Commentary Comment.
Commission Comm’n
Commissioner Comm’r
Committee Comm.
Communication Commc’n
Community Cmty.
Company Co.
Comparative Compar.
Compensation Comp.
Condominium Condo.
Conference Conf.
Consolidated Consol.
Construction Constr.
Contemporary Contemp.
Continental Cont’l
234
H. TABLES
Contract Cont.
Cosmetic Cosm.
County Cnty.
Department Dep’t
Detention Det.
Digest Dig.
Digital Digit.
Diplomacy Dipl.
Director Dir.
Discount Disc.
Dispute Disp.
District Dist.
Division Div.
Doctor Dr.
235
The Indigo Book
East, Eastern E.
Enforcement Enf’t
Engineer Eng’r
Engineering Eng’g
English Eng.
Enterprise Enter.
Entertainment Ent.
Equality Equal.
Equipment Equip.
Estate Est.
Examiner Exam’r
Exchange Exch.
Executive Exec.
Faculty Fac.
Federal Fed.
Federation Fed’n
236
H. TABLES
Fidelity Fid.
Fortnightly Fort.
Forum F.
Foundation Found.
General Gen.
Global Glob.
Government Gov’t
Group Grp.
Hispanic Hisp.
Hospital Hosp.
Hospitality Hosp.
Housing Hous.
Human Hum.
Incorporated Inc.
Indemnity Indem.
Inequality Ineq.
Information Info.
Insurance Ins.
237
The Indigo Book
Intellectual Intell.
Intelligence Intel.
Interdisciplinary Interdisc.
Interest Int.
International Int’l
Journal, Journals J.
Judicial Jud.
Juridicial Jurid.
Jurisprudence Juris.
Justice Just.
Juvenile Juv.
Labor Lab.
Laboratory Lab’y
Law (unless it is the the first word, in which case do not abbreviate) L.
Lawyer Law.
Liability Liab.
Limited Ltd.
Litigation Litig.
Local Loc.
238
H. TABLES
Magazine Mag.
Maintenance Maint.
Management Mgmt.
Manufacturer Mfr.
Manufacturing Mfg.
Maritime Mar.
Market Mkt.
Marketing Mktg.
Matrimonial Matrim.
Memorial Mem’l
Metropolitan Metro.
Military Mil.
Mineral Min.
Modern Mod.
Mortgage Mortg.
Mutual Mut.
National Nat’l
Nationality Nat’y
Natural Nat.
Negligence Negl.
239
The Indigo Book
Newsletter Newsl.
North, Northern N.
Number No.
Opinion Op.
Order Ord.
Pacific Pac.
Parish Par.
Partnership P’ship
Patent Pat.
Perspective Persp.
Planning Plan.
Policy Pol’y
Problems Probs.
240
H. TABLES
(Note: Consider maintaining the more traditional “Prof.” or “Prof’l” rather than
“Pro.” in context.) See Table T15, which prioritizes “Prof.” for specific periodical
titles.)
Property Prop.
Protection Prot.
Public Pub.
Publication Publ’n
Publishing Publ’g
Quarterly Q.
Railroad R.R.
Railway Ry.
Record Rec.
Referee Ref.
Regional Reg’l
Register Reg.
Relation Rel.
241
The Indigo Book
Research Rsch.
Resolution Resol.
Responsibility Resp.
Restaurant Rest.
Retirement Ret.
Rights Rts.
Road Rd.
Savings Sav.
School Sch.
Scottish Scot.
Secretary Sec’y
Sentencing Sent’g
Service Serv.
Social Soc.
Society Soc’y
Solicitor Solic.
Solution Sol.
242
H. TABLES
South, Southern S.
Street St.
Studies Stud.
Subcommittee Subcomm.
Surety Sur.
Taxation Tax’n
Teacher Tchr.
Telecommunication Telecomm.
Temporary Temp.
Township Twp.
Transcontinental Transcon.
Transnational Transnat’l
Tribune Trib.
Turnpike Tpk.
Uniform Unif.
243
The Indigo Book
University Univ.
(case names)
University U.
(periodical
titles)
Urban Urb.
Utility Util.
Village Vill.
Week Wk.
Weekly Wkly.
West, Western W.
Place Abbreviation
States
Alabama Ala.
Alaska Alaska
Arizona Ariz.
Arkansas Ark.
244
H. TABLES
Place Abbreviation
California Cal.
Colorado Colo.
Connecticut Conn.
Delaware Del.
Florida Fla.
Georgia Ga.
Hawaii Haw.
Idaho Idaho
Illinois Ill.
Indiana Ind.
Iowa Iowa
Kansas Kan.
Kentucky Ky.
Louisiana La.
Maine Me.
Maryland Md.
Massachusetts Mass.
Michigan Mich.
Minnesota Minn.
Mississippi Miss.
Missouri Mo.
Montana Mont.
Nebraska Neb.
Nevada Nev.
245
The Indigo Book
Place Abbreviation
Ohio Ohio
Oklahoma Okla.
Oregon Or.
Pennsylvania Pa.
Tennessee Tenn.
Texas Tex.
Utah Utah
Vermont Vt.
Virginia Va.
Washington Wash.
Wisconsin Wis.
Wyoming Wyo.
Cities
Baltimore Balt.
Boston Bos.
Chicago Chi.
246
H. TABLES
Place Abbreviation
Dallas Dall.
Houston Hous.
Miami Mia.
Philadelphia Phila.
Phoenix Phx.
Territories
Guam Guam
Australia
Queensland Queensl.
Tasmania Tas.
Victoria Vict.
247
The Indigo Book
Place Abbreviation
Canada
Alberta Alta.
Manitoba Man.
Nunavut Nun.
Ontario Ont.
Quebec Que.
Saskatchewan Sask.
Yukon Yukon
Afghanistan Afg.
Africa Afr.
Albania Alb.
Algeria Alg.
Andorra Andorra
Angola Angl.
Anguilla Anguilla
Antarctica Antarctica
248
H. TABLES
Place Abbreviation
Argentina Arg.
Armenia Arm.
Asia Asia
Australia Austl.
Austria Austria
Azerbaijan Azer.
Bahamas Bah.
Bahrain Bahr.
Bangladesh Bangl.
Barbados Barb.
Belarus Belr.
Belgium Belg.
Belize Belize
Benin Benin
Bermuda Berm.
Bhutan Bhutan
Bolivia Bol.
Botswana Bots.
Brazil Braz.
Brunei Brunei
Bulgaria Bulg.
Burundi Burundi
249
The Indigo Book
Place Abbreviation
Cambodia Cambodia
Cameroon Cameroon
Canada Can.
Chad Chad
Chile Chile
Colombia Colom.
Comoros Comoros
Croatia Croat.
Cuba Cuba
Cyprus Cyprus
Denmark Den.
Djibouti Djib.
Dominica Dominica
Ecuador Ecuador
Egypt Egypt
250
H. TABLES
Place Abbreviation
El Salvador El Sal.
England Eng.
Eritrea Eri.
Estonia Est.
Ethiopia Eth.
Europe Eur.
Fiji Fiji
Finland Fin.
France Fr.
Gabon Gabon
Gambia Gam.
Georgia Geor.
Germany Ger.
Ghana Ghana
Gibraltar Gib.
Greece Greece
Greenland Green.
Grenada Gren.
Guadeloupe Guad.
Guatemala Guat.
Guinea Guinea
Guinea-Bissau Guinea-Bissau
251
The Indigo Book
Place Abbreviation
Guyana Guy.
Haiti Haiti
Honduras Hond.
Hungary Hung.
Iceland Ice.
India India
Indonesia Indon.
Iran Iran
Iraq Iraq
Ireland Ir.
Israel Isr.
Italy It.
Jamaica Jam.
Japan Japan
Jordan Jordan
Kazakhstan Kaz.
Kenya Kenya
Kiribati Kiribati
Kosovo Kos.
Kuwait Kuwait
Kyrgyzstan Kyrg.
Laos Laos
252
H. TABLES
Place Abbreviation
Latvia Lat.
Lebanon Leb.
Lesotho Lesotho
Liberia Liber.
Libya Libya
Liechtenstein Liech.
Lithuania Lith.
Luxembourg Lux.
Macau Mac.
Macedonia Maced.
Madagascar Madag.
Malawi Malawi
Malaysia Malay.
Maldives Maldives
Mali Mali
Malta Malta
Martinique Mart.
Mauritania Mauritania
Mauritius Mauritius
Mexico Mex.
Micronesia Micr.
Moldova Mold.
Monaco Monaco
Mongolia Mong.
253
The Indigo Book
Place Abbreviation
Montenegro Montenegro
Montserrat Montserrat
Morocco Morocco
Mozambique Mozam.
Myanmar Myan.
Namibia Namib.
Nauru Nauru
Nepal Nepal
Netherlands Neth.
Nicaragua Nicar.
Niger Niger
Nigeria Nigeria
Norway Nor.
Oman Oman
Pakistan Pak.
Palau Palau
Panama Pan.
Paraguay Para.
Peru Peru
Philippines Phil.
254
H. TABLES
Place Abbreviation
Poland Pol.
Portugal Port.
Qatar Qatar
Réunion Réunion
Romania Rom.
Russia Russ.
Rwanda Rwanda
Samoa Samoa
Scotland Scot.
Senegal Sen.
Serbia Serb.
Seychelles Sey.
Singapore Sing.
Slovakia Slovk.
Slovenia Slovn.
Somalia Som.
255
The Indigo Book
Place Abbreviation
Spain Spain
Sudan Sudan
Suriname Surin.
Swaziland Swaz.
Sweden Swed.
Switzerland Switz.
Syria Syria
Taiwan Taiwan
Tajikistan Taj.
Tanzania Tanz.
Thailand Thai.
Togo Togo
Tonga Tonga
Tunisia Tunis.
Turkey Turk.
Turkmenistan Turkm.
Tuvalu Tuvalu
Uganda Uganda
Ukraine Ukr.
256
H. TABLES
Place Abbreviation
Uruguay Uru.
Uzbekistan Uzb.
Vanuatu Vanuatu
Venezuela Venez.
Vietnam Viet.
Wales Wales
Yemen Yemen
Zambia Zam.
Zimbabwe Zim.
addendum add.
amendment amend.
annotation annot.
article art.
bibliography bibliog.
book bk.
chapter ch.
clause cl.
257
The Indigo Book
column col.
comment[ary] cmt.
decision dec.
department dept.
division div.
example ex.
figure fig.
folio fol.
hypothetical hypo.
illustration[s] illus.
introduction intro.
number no.
paragraph[s] ¶, ¶¶
part pt.
preamble pmbl.
principle princ.
publication pub.
rule r.
258
H. TABLES
schedule sched.
subdivision subdiv.
subsection subsec.
supplement supp.
table tbl.
title tit.
volume vol.
Abbreviated Phrase
acq.
acq. in result
aff’d,
aff’d mem.,
aff’d on reh’g,
aff’g
amended by
appeal denied,
appeal dismissed,
259
The Indigo Book
Abbreviated Phrase
appeal docketed,
appeal filed,
argued,
cert. denied,
cert. dismissed,
cert. granted,
certifying questions to
denying cert. to
enforced,
enforcing
invalidated by
mandamus denied,
modified,
modifying
nonacq.
overruled by
rev’d,
260
H. TABLES
Abbreviated Phrase
rev’g
vacated,
vacating as moot
withdrawn,
Related tables are Table T11 with common words and Table T12 with geographical
abbreviations.
Adelaide Adel.
Albany Alb.
Brooklyn Brook.
Buffalo Buff.
261
The Indigo Book
Capital Cap.
Chapman Chap.
Cincinnati Cin.
Cleveland Clev.
Columbia Colum.
Cumberland Cumb.
Denver Denv.
Detroit Det.
Dickinson Dick.
Duquesne Duq.
East, Eastern E.
Georgetown Geo.
Gonzaga Gonz.
Harvard Harv.
Howard How.
262
H. TABLES
Loyola Loy.
Marquette Marq.
Melbourne Melb.
Memphis Mem.
North, Northern N.
Pepperdine Pepp.
Pittsburgh Pitt.
Richmond Rich.
South, Southern S.
Stanford Stan.
Temple Temp.
263
The Indigo Book
Toledo Tol.
Tulane Tul.
Valparaiso Val.
Vanderbilt Vand.
Villanova Vill.
West, Western W.
annotated ann.
anonymous anon.
circa c.
copyright copy.
draft drft.
264
H. TABLES
manuscript ms.
mimeograph mimeo.
no date n.d.
no place n.p.
no publisher n. pub.
offprint offprt.
permanent perm.
printing prtg.
replacement repl.
reprint reprt.
special spec.
temporary temp.
tentative tent.
unabridged unabr.
volume vol.
January Jan.
February Feb.
265
The Indigo Book
Month NameAbbreviation
March Mar.
April Apr.
May May
June June
July July
August Aug.
September Sept.
October Oct.
November Nov.
December Dec.
Word Abbreviation
Admission Admis.
Affirm Affirm
Amended Am.
Answer Answer
Appeal Appeal
Appellant Appellant
Appellee Appellee
Appendix App.
Application Appl.
Argument Arg.
266
H. TABLES
Attachment Attach.
Attorney Att’y
Brief Br.
Certiorari Cert.
Civil Civ.
Compel Compel
Counterclaim Countercl.
Court Ct.
Cross-claim Cross-cl.
Declaration Decl.
Demurrer Dem.
Deposition Dep.
Discovery Disc.
Dismiss Dismiss
Docket Docket
Evidence Evid.
Exhibit Ex.
Grant Grant
Hearing Hr’g
Injunction Inj.
Instruction Instr.
Interrogatory Interrog.
267
The Indigo Book
Judgment J.
Limine Lim.
Memorandum Mem.
Minute Min.
Motion Mot.
Objection Obj.
Opinion Op.
Opposition Opp’n
Order Order
Petition Pet.
Preliminary Prelim.
Quash Quash
Reconsideration Recons.
Record R.
Rehearing Reh’g
Reply Reply
Reporter Rep.
Request Req.
Respondent Resp’t
268
H. TABLES
Response Resp.
Stay Stay
Subpoena Subpoena
Summary Summ.
Suppress Suppress
Testimony Test.
Transcript Tr.
State Ga. Const. art VIII, § IV. GA. CONST. art VIII, § IV.
constitution
Session laws FASTER Act of 2021, Pub. L. No. FASTER Act of 2021, Pub. L. No.
117-11, 135 Stat. 262 (2021). 117-11, 135 Stat. 262 (2021).
Bill (not H.R. 3054, 117th Cong. (2021). H.R. 3054, 117th Cong. (2021).
enacted)
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The Indigo Book
State statute Colo. Rev. Stat. § 13-90-107 (2021). COLO. REV. STAT. § 13-90-107 (2021).
State statute N.Y. Gen. Bus. Law § 349 (McKinney N.Y. GEN. BUS. LAW § 349 (McKinney
with topic 2021). 2021).
convention
Federal and South Dakota v. Wayfair, Inc., 138 S. If used in the main text, the case name
state cases Ct. 2080 (2018). is italicized.
Pincheira v. Allstate Ins. Co., 190 P.3d If cited in a footnote, the case name is
322 (N.M. 2008). in regular roman type (not italicized):
Pending or Facteau v. Clinton Cnty. Bd. of If used in the main text, the case name
unreported case Elections, No. 533784, 2021 WL is italicized.
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H. TABLES
Pending case Sportswear, Inc. v. Savannah Coll. of If used in the main text, the case name
(petition for Art & Design, 983 F.3d 1273 (11th Cir. is italicized.
certiorari filed) 2020), petition for cert. filed 89
If cited in a footnote:
U.S.L.W. 3344 (U.S. March 31, 2021)
(No. 20-1391). Sportswear, Inc. v. Savannah Coll. of
Art & Design, 983 F.3d 1273 (11th Cir.
Or:
2020), petition for cert. filed, 89
Sportswear, Inc. v. Savannah Coll. of U.S.L.W. 3344 (U.S. March 31, 2021)
Art & Design, 983 F.3d 1273 (11th Cir. (No. 20-1391).
2020), petition for cert. filed (No.
20-1391),
https://www.scotusblog.com/case-
files/cases/sportswear-inc-v-
savannah-college-of-art-and-design-
inc-2/.
State case with State v. Blagg, 2021-NCSC-66, ¶ 15, If used in the main text, the case name
public-domain 858 S.E.2d 268, 274. is italicized.
parallel citation
If cited in a footnote:
and year
embedded in State v. Blagg, 2021-NCSC-66, ¶ 15,
citation 858 S.E.2d 268, 274.
Book Anjali Vats, The Color of Creatorship: ANJALI VATS, THE COLOR OF
Intellectual Property, Race, and the CREATORSHIP: INTELLECTUAL
Making of Americans (2020). PROPERTY, RACE, AND THE MAKING OF
AMERICANS(2020).
Chapter in a Sung Hui Kim, The Ethics of In-House Sung Hui Kim, The Ethics of In-House
collected work Practice, in Lawyers in Practice: Practice, in LAWYERS IN PRACTICE:
271
The Indigo Book
Journal article Elizabeth G. Porter & Kathryn A. Elizabeth G. Porter & Kathryn A.
Watts, Visual Rulemaking, 91 N.Y.U. Watts, Visual Rulemaking, 91 N.Y.U.
(with
L. Rev. 1183 (2016). L. REV. 1183 (2016).
consecutive
pagination, as
common with
law reviews)
Journal or Elizabeth Kolbert, The Lost Canyon, Elizabeth Kolbert, The Lost Canyon,
magazine article New Yorker, Aug. 16, 2021, at 40, 42. NEW YORKER, Aug. 16, 2021, at 40, 42.
(nonconsecutive
pages)
Newspaper Adam Liptak, Supreme Court Rules Adam Liptak, Supreme Court Rules
for Cheerleader Punished for Vulgar for Cheerleader Punished for Vulgar
Snapchat Message, N.Y. Times, June Snapchat Message, N.Y. TIMES, June
23, 2021, at A1. 23, 2021, at A1.
Internet Farhad Manjoo, Why You Should Farhad Manjoo, Why You Should
Never, Ever Use Two Spaces After a Never, Ever Use Two Spaces After a
Period, Slate (Jan. 11, 2011, 6:00 AM), Period, SLATE (Jan. 11, 2011, 6:00
https://slate.com/technology/2011/ AM), https://slate.com/technology/
01/two-spaces-after-a-period-why- 2011/01/two-spaces-after-a-period-
you-should-never-ever-do-it.html why-you-should-never-ever-do-it.html
272
H. TABLES
1. New Zealand Law Foundation, New Zealand Law Style Guide, 2nd Edition, (2011).
2. Faulty of Law, University of Oxford, Oxford University Standard for Citation of Legal
Authorities (2006).
3. SILC, Standard Indian Legal Citation (Working Draft).
4. University of Melbourne, Australian Guide to Legal Citation (4th ed. 2018).
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I. CODICIL
Editor’s Note (2021): The Codicil will be updated with additional information about the Second
Edition. This is the Codicil from the First Edition.
The Indigo Book: A Manual of Legal Citation is distributed as a single document coded with
the HTML 5 and Cascading Style Sheet (CSS) standards.
Each rule and section of the file have a unique ID, making them individually addressable.
Examples are:
• Each Rule has an ID starting with the letter R and then the rule number. For example,
Rule 1.1 can be addressed by adding #R1.1 to the URL.
• Each Section has an ID starting with the letter S and then the rule letter. For example,
the Codicil can be addressed by adding #SK to the URL.
• Each Table has an ID starting with the letter T and then the table number. For example,
Table T1.1 can be addressed by adding #T1.1 to the URL.
The header of the file calls two open source Google fonts. If those fonts are not available, the
CSS style sheet falls back to Georgia, which is present on most computers, and then to the
generic serif font. The fonts we use are:
• For the cover, Alice, which was designed by Ksenia Erulevich and inspired by Lewis
Carrol's novel.
• For the body of the document, Libre Baskerville, based on the 1941 American Type
Founder's Baskerville, but optimized for web use.
To clearly distinguish our work from other citation manuals, we have forgone the use of the
color Royal Blue in favor of Indigo, in solidarity with the ryots of Bengal who were oppressed
by the insatiable British demand for blue and the profits that flowed from it, leading to the
Nilbridroha (Indigo revolt) and the beginning of the road that led to independence.
The CSS has been coded with support for printing on US Letter size paper. We use Prince XML
to convert the HTML document to PDF format.
It is also possible to dynamically change the styles to perform tasks such as making all text in
italics “pop” by turning it crimson or back to normal.
To create a file for use in Microsoft Word, an easy method is to comment out the calls to Google
fonts, upload the document to Google Docs, and then downloading it in Word format.
274
J. ACKNOWLEDGMENTS
J. ACKNOWLEDGMENTS
The Second Edition of The Indigo Book: A Manual of Legal Citation (2021) was edited by
Professor Jennifer Murphy Romig. Professor Romig was assisted by Emory University School
of Law students Annabelle Bichler, Nancy Jin, and Akhil Morissetti, as well as Daniel Kaltman.
Professor Romig would also like to thank Mindy Goldstein, Mark T. Gray, Mike Lissner, Amber
Madole, Olivia Marbutt, Sue Payne, Robin Pederson, Blake Reid, Heather Simmons, Allison
Thornton, and David Ziff for valuable comments and feedback, as well as Christopher
Sprigman for his insightful feedback, wise counsel, and steadfast support of The Indigo Book.
Professor Romig thanks Jeannette Livingston for exploring the ins and outs of Microsoft Word
to assist this project. Professor Romig is grateful to Ben Chapman and Zach Stevenson for
technical advice, and of course Frank Bennett and Carl Malamud. Professor Romig is also
grateful to her daughter Laura Romig for proofreading assistance and helpful feedback.
275