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The editors provide authoritative guidance to reasonable questions on subjects covered by The Bluebook. The most useful answers are gathered here as Blue Tips, classified by subject. These tips are searchable and linked to the Bluebook content they address. Send your questions to [email protected]. If our answer is useful to Bluebookers generally, it may be formulated into a new tip, below.

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Cases Citation Structure Cross-References Miscellany Periodicals Punctuation Quotations Signals Statutes Subdivisions

CASES
United States and U.S., 1/2/2008 (Related Sections: R10.2.2, T.6) United States is never abbreviated when the United States is a party in a case name. However, it may be abbreviated as part of another partys name, like any other word in T.11. In textual sentences, U.S. may be used as an adjective, but it should never be used as a noun. For example: United States v. Church of Scientology W. U.S., 973 F.2d 715 (9th Cir. 1992). Citing to Two Cases That Share a Single Citation., 1/2/2008 (Related Section: R10.2.2)

When citing two cases with the same citation that have not been consolidated cite as X v. Y and A v. B. For an example of this relatively rare phenomenon, see The Supreme Court: 1996 Term Leading Cases, 111 HARV. L. REV. 197, 243 n.65.
Dates of pre-1882 U.S. Supreme Court Cases, 1/2/2008 (Related Sections: R10.5, T.1) Before Volume 108 of the U.S. Reports (1882), opinions do not list their date of decision but list only the Term in which they were decided. For the dates of these opinions, you must refer to the Librarian of the Supreme Courts list of dates, which is found at http://www.supremecourtus.gov/opinions/datesofdecisions.pdf. Nonprofit Parties in Case Names, 1/2/2008 (Related Section: R10.2.1) The names of nonprofit corporations as parties should be treated like any other business name, such that references to geographic location should not be dropped and business firm designations should generally be retained. For example: See Hurley v. Irish-Am. Gay, Lesbian and Bisexual Group of Boston, Inc., 515 U.S. 557 (1995). Plurality Opinions, 1/2/2008 (Related Sections: R10.6.1, R10.7.1)

Carefully scan the beginning of opinions to determine if any part of the principal opinion has been endorsed by less than a majority of the court. If so, be sure that any pincite to a portion of the opinion enjoying less-than-majority support is designated as (plurality opinion). (The header in recent volumes of the U.S. Reports will change from page to page depending on whether the principal opinion is endorsed by a majority of the Court.) Treat the (plurality opinion) designation as identical to a concurring or dissenting parenthetical both for purposes of full and short citations. Therefore, (plurality opinion) should be included in all short citations other than id. when the plurality opinion was also cited in the previous footnote. Similarly, (plurality opinion) should not be included when the case is cited in full without a pincite. These two examples are wrong: The Court was badly splintered in Troxel v. Granville, 530 U.S. 57 (2000) (plurality opinion), with no opinion commanding a majority of the Court; 1 See Troxel, 530 U.S. at 65 (noting the longstanding nature of the liberty interest in rearing ones child). This example is correct: 1 See Troxel, 530 U.S. at 65 (plurality opinion) (noting the longstanding nature of the liberty interest in rearing ones child).
Seriatim Opinions of the Early U.S. Supreme Court, 2/8/2008 (Related Section: T.1) Prior to the Marshall Court, the Supreme Court followed the traditional British practice of each Justice writing his own opinion rather than producing a majority opinion for the Court. To cite such an opinion, include the parenthetical (opinion of Lastname, J.). Short Forms and Concurring and Dissenting Opinions, 1/2/2008 (Related Sections: R4.1, R10.9)

As indicated in Bluebook Rule 10.9(b)(i), when citing a decision other than the majority opinion of the court, include a parenthetical identifying the author and the status of the opinion. Immediate subsequent citations to the same case (using id.) are presumed to be citing to the same nonmajority opinion. To switch from one nonmajority opinion to another nonmajority opinion, you need only insert a different parenthetical. If a citation to the majority opinion is immediately subsequent to a citation to a nonmajority opinion, you must include (majority opinion) after the id. citation. For example: 10Kiowa Tribe, 118 S. Ct. at 1706 (Stevens, J., dissenting). 11Id. at 1707. 12Id. at 1705 (OConnor, J.,

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The (mem.) Designation, 1/2/2008 (Related Section: R10.6.1) As stated at Rule 10.6.1(b), a decision is designated (mem.) only when it is issued without opinion. It should be included each time the full citation to the decision is given, even when the decision has been cited earlier in the piece but not within five footnotes. Typically, this designation will only be used for stand-alone (i.e., not as part of a subsequent history phrase) citations to denials of certiorari. Citations to written dissents from or concurrences with decisions issued without an opinion should not include the (mem.) designation. District court or other opinions denominated memorandum decision are not designated (mem.).

CITATION STRUCTURE
Citations Within Parentheticals, 1/30/2008 (Related Sections: R4, R10.6, R10.9) When citations occur within parentheticals, special attention must be paid to formatting and punctuation. In addition, the following points must be observed: First, a chain of id.-based short citations is not broken by a parenthetical citation to a different source. Second, and for the same reason, where an id. citation follows a citation with a parenthetical citation to another source, the id. refers to the main citation, not the parenthetical citation. Third, a parenthetical citation does count as a citation for purposes of the five-footnote rule for determining whether to use a short form citation for cases (Rule 10.9(a)). Finally, when a parenthetical citation is the first of several cites to a source for which the supra form may be used, the supra citations should generally relate back to the first nonparenthetical citation, for the ease of the reader. Order of Articles and Student-Written Pieces, 2/15/2008 (Related Section: R1.4) For articles and student written pieces, two or more works by the same author are ordered first by type (e.g., books before articles), then alphabetically by title (excluding A, An, and The); unsigned articles or notes are alphabetized as though the first word in the title (excluding A, An, and The) were the authors name; and if works by author X are cited in the same string citation as works by authors X & Y (i.e., the same author and a collaborator), the works by X & Y follow the works by X alone. Order of Parentheticals in a Single Citation, 1/2/2008 (Related Section: R1.5) When a citation requires multiple parentheticals, place them in the following order: (date) [hereinafter some 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), available at http://www.domainname.com (explanatory parenthetical). In direct citations to internet sources, the hereinafter parenthetical should immediately follow the URL or, if there is one, the last visited parenthetical. Related Authority Follows Explanatory Parentheticals, 1/8/2008 (Related Sections: R1.5, R1.6)

Explanatory parentheticals precede all related authority. For example: Louis Loss, The Conflict of Laws and the Blue Sky Laws, 71 HARV. L. REV. 209 (1957) (discussing the bewildering array of state laws then governing interstate securities transactions), reprinted in LOUIS LOSS & EDWARD M. COWETT, BLUE SKY LAW 180 (1958).
Unpublished Opinions Cited with Published Opinions, 1/2/2008 (Related Section: R1.4)

Unpublished opinions have the same status as published opinions for purposes of order within a signal.

CROSS-REFERENCES
At Not Used in Short Citations to Constitutions, 1/20/2008 (Related Section: R11) For citations to constitutions using id., do not use an at before the pincite. That is, See id. at art. III, 2 is incorrect, and See id. art. III, 2 is correct. Citation of internal footnotes, 1/2/2008 (Related Section: R4.2) For clairity, it is best not to refer a reader directly to a footnote (See supra note X) unless the footnote contains some new material written by the author. If the footnote contains only cases, the clearest form is See cases cited supra note X. If the footnote contains other authorities in addition to or in place of cases, use the form: See sources cited supra note X. If the footnote contains only a single source (and no non-parenthetical commentary by the author), direct citation of that source is preferable. Five-Footnote Rule, 2/15/2008 (Related Section: R4.1)

If the case has been cited (not referred to textually) anywhere in the preceding five footnotes (including in a (citing) or (quoting) parenthetical or a citation of a brief or oral argument from that case), use a short form citation. An id. citation within the previous five footnotes does count if its referring to the case in question. When counting footnotes for the purposes of this rule, count all five of the preceding footnotes. For example, if the case in question is in note 49, references in notes 4448 count for

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MISCELLANY
Photographs, 1/2/2008 (Related Sections: R15.8, R16.6) When citing a photograph that appears on an unnumbered page, use Photograph of [a description] and give the full cite to the work, followed by following p. [whatever numbered page immediately precedes the photo]. If the photograph has a title, it should be in italics (followed by a parenthetical). Include the photographers name if significant or relevant. For example: See Photograph of Bill Clinton and President Kennedy, in David Maraniss, First in His Class (1994), following p. 134; see also Ansel Adams, Bridal Veil Fall (photograph), in Yogi Bear, Jellystone Park and Its Rivals (1960), following p. 21.

PERIODICALS
Opinion Pieces, 1/22/2008 (Related Section: R16.5)

As stated in Rule 16.5(a)(i), note parenthetically when a cited newspaper item is an opinion piece, such as an editorial, or an op-ed. Use Letter to the Editor rather than any peculiar form that the periodical may use (such as Saturday Mailbag or 20071).

PUNCTUATION
Footnote Call and Parenthetical Arrangement, 1/2/2008 (Related Section: R1.1) Footnote calls always go before parenthetical abbreviations or shorthand notations. Here are two examples: Recently, in In re Walt Disney Co. Derivative Litigation1 (Disney IV), the Delaware Court of Chancery determined that the officers and directors of the Walt Disney Company did not breach their fiduciary duties; The Supreme Court recently held that the Age Discrimination in Employment Act of 19671 (ADEA) creates a disparate impact claim. Footnote Call and Punctuation Arrangement, 1/2/2008 (Related Section: R1.1)

Footnote calls always go outside quotation marks. Colons and semicolons also go outside. The proper order is: quotation mark, semicolon, footnote call, colon. Commas, however, go inside quotation marks.

QUOTATIONS
Quotations in Parentheticals, 1/2/2008 (Related Section: R5.1) The 50+ word rule (R5.1(a)) does not apply to quotations in parentheticals; there is no need to indent such quotations. However, if a quotation in a parenthetical is overly long or cumbersome, consider using a textual sentence. Repeated Quotations, 1/2/2008 (Related Section: R5.1) When an author repeatedly uses certain quoted material (such as when, in an article about a specific constitutional provision, the author regularly quotes the provision in question), a footnote generally needs to be included only the first time the quotation is included in the material. If there has been a significant gap since the previous use, however, a repeated citation may be appropriate.

SIGNALS
"Compare" Requires "With", 1/2/2008 (Related Section: R1.2) In Compare citations, there must always be a with. The with (or and) is preceded by a comma. For example: Compare Tom (blonde), and Tina (same), with Huey (duck), Dewey (same), and Louie (same). E.g. used with other signals, 1/8/2008 (Related Section: R1.2) E.g. may be used alone or attached to any other signal (whether supportive or not), preceded by a comma, and followed by a non-italicized comma. Thus the following are correct: See, e.g.; See also, e.g.; Cf., e.g.; Compare, e.g.; But see, e.g. Also, however cannot be added to any signal other than see.

STATUTES
Acts Comprising Only Part of a Broader Statute, 1/2/2008 (Related Sections: R12.2, R12.3, R12.4)

When a specific act was passed as a subdivision (such as one title or one section) of a broader statute, the session law citation of the specific act should list the subdivision of broad statute in which the specific act is found, but should treat the first page of that subdivision as the page on which the act

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begins. A pincite to a section of the specific act should both include the subdivision reference to the specific act as a whole and the exact section number in question. Both of the following examples are correct: See Violence Against Women Act, Pub. L. No. 103-322, tit. IV, 108 Stat. 1902 (1994) (codified as amended in scattered sections of 8, 16, 18, 28, and 42 U.S.C.). See Violence Against Women Act, Pub. L. No. 103-322, tit. IV, 40302, 108 Stat. 1902, 194142 (1994) (codified at 42 U.S.C. 13981 (2000)), invalidated by United States v. Morrison, 529 U.S. 598 (2000).
Acts With Dates in Their Official Titles, 1/2/2008 (Related Section: R12.3.1) The first reference to a statute should always use its official title as designated by Congress including the year of the statute if it is in the official title (even if the statute has been subsequently amended in a later year). Hint: The Popular Name Table in Westlaw (database identifier USCA-POP) and Lexis lists these official titles. For example: Endangered Species Act of 1973, 16 U.S.C. 15331544 (2000). Using "Id." with Statutes, 1/2/2008 (Related Sections: R4.1, R12.9) Id. should be used with statutes only when citing the same title of the same series. Thus, this example is wrong: 42 U.S.C. 1983 (1988); see also 5 id. 303 (1976). The following two examples are right: 42 U.S.C. 1983 (1988); see also id. 1984. 42 U.S.C. 1983 (1988); see also 42 U.S.C.A. 1984 (West 1985 & Supp. 1990). When citing the name and original section numbers of an act, use id. in the following manner: EPA 211, 43 U.S.C. 435 (1976); see also id. 212, 43 U.S.C. 436. EPA, Pub. L. No. 94-123, 211, 21 Stat. 65, 66 (1975) (codified as amended at 43 U.S.C. 435 (1994)); see also id. 212, 21 Stat. at 67 (codified as amended at 43 U.S.C. 436).

SUBDIVISIONS
Dropping Repetitious Digits, 1/15/2008 (Related Section: R3.2)

Rule 3.2(a) applies only to consecutive page and note numbers and only when non-repetitious digits appear only in the units or tens position of the number. Do not drop repetitious digits from consecutive section or paragraph numbers, sections of statutes, or years. Both of the following examples are incorrect: [19791980 Transfer Binder] Fed Sec. L. Rep. (CCH) 57893; Curtis A. Bradley & Jack L. Goldsmith, Congressional Authorization and the War on Terrorism, 118 HARV. L. REV. 2048, 2096100 (2005). Note that while repetitious digits in the units or tens positions may not be dropped from section and paragraph numbers, identical digits or letters preceding any punctuation mark may be omitted, so long as doing so does not create confusion. See Bluebook rules 3.3(b) and 3.3(c). This example is correct: WASH. REV. CODE ANN. 18.51.005.52.900 (West 1989 & Supp. 1991).
Pinciting, 1/2/2008 (Related Section: R3.2) Readers should be able to find and verify the accuracy of a citation rapidly. Use a pincite whenever a subset of the cited authority supports the proposition or contains the quotation mentioned in the text. Generally, cite the smallest subset that supports the relevant proposition. Pincites identifying particular quotations or points should follow rather than precede the quotation or point. If a sentence identifies the authority before it presents the quotation or point from that authority, use two citations. Ranges of Star-Paginated Material, 1/2/2008 (Related Section: R3.2) If a source uses star paging (such as *3), drop the star in the reference to the ending page number (for example, *35) but keep the star in all references to nonconsecutive pages (for example, *3, *5).

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