Bluebook Legal Citation

In certain circumstances, it is permissible to use a shortened citation to a previously cited authority.  These citations are referred to as "short form" citations. 

This page will discuss some general rules to follow for short form citations, but note that different types of documents will have specific rules governing appropriate short forms.  In this guide, these special short form rules are covered with other rules relevant to each type of document.

Although not technically a short form, "infra" can also be used to refer to material that appears later in the same text. Confusingly, the Bluebook does not discuss "infra" in any section of Rule 4. Brief examples and instructions for the use of "infra" can be found in Rule 3.5.

Below is a table listing authority types covered in this guide, cross-referenced with the corresponding bluebook rule.

Bluebook Rule (21st): 4.1

Law Review Typeface: Italics (including the period)

"Id." is an all-purpose short form citation that may be used for any cited authority except internal cross-references.

"Id." always refers to the immediately preceding cited authority, either in the same footnote or the previous footnote so long as it is the only authority cited in the preceding footnote.

Sweatt v. Painter, 339 U.S. 629, 632 (1950).

Id.

NOTE: Sources cited in explanatory parentheticals or phrases or as part of a case prior or subsequent history are not counted as intervening authorities preventing the use of "Id."

Any change in what is being cited, such as page numbers, needs to be indicated after "Id."

Id. at 45.

Bluebook Rule (21st): 4.2(a)

Law Review Typeface: Italics

"Supra" may be used to refer to certain types of previously cited materials as well as internal cross-references.  Rule 4.2 contains a complete, detailed list of which materials may and may not be cited to using "Supra."  Note, however, that in general most forms of primary legal authority (cases, statutes, etc.) should not be referred to using "Supra." 

NOTE: This is also true for materials such as restatements, legislative documents (other than hearings), and model codes which typically have similar citation formats.

"Supra" citations are most commonly used for secondary authority, such as books and periodicals.  Therefore, the most common format for a Supra short form citation consists of the author's last name followed "supra," offset by a comma.  Immediately after "supra" is the word "note" in ordinary type, followed by the number of the footnote in which the authority was first cited in full:

 15. Philip D. O'Neill, Jr., Verification in an Age of Insecurity: The Future of Arms Control Compliance 45 (2010).

25. O'Neill, supra note 15.

A pincite offset by a comma should indicate changes in what portion of the authority is being cited.  An "at" is typically necessary to avoid confusion:

28. O'Neill, supra note 15, at 52.

If a work has an institutional author, use the complete institutional name; works without an author may be cited to by the title, while unsigned student authored law journal works should be cited by the appropriate designation such as "Note" or "Comment."

NOTE: The typeface convention from the original source should be used for the author name or title in a "supra" citation.

Bluebook Rule (21st): 4.2(b)

Law Review Typeface: Varies by source  

The term "hereinafter" is used when using another short form would be impractical, cumbersome, or confusing.

Two typical circumstances where a "hereinafter" is appropriate are when an author name or title is long and unwieldy for a normal "supra" short form citation and to distinguish between two or more authorities cited originally in the same footnote which could easily be confused with each other.

To use "hereinafter," at the end of the first full citation and enclosed in square brackets, but before any explanatory parenthetical, and write "hereinafter" followed by a shortened form of the authority, typically a paraphrase of the title or designation of the type of document as long as unambiguous.

NOTE: The shortened "hereinafter" form should be in the same typeface as the original.

Subsequent citations to the authority will function as supra citations but will use the hereinafter designation in place of the full author or title.

Bluebook Rule (21st): 3.5

Law Review Typeface: Italics 

Internal cross-references are used to cite to text and notes within the same work.  Internal cross-references may point the reader to specific pages, designate parts and sections, paragraphs, or footnotes, as well as figures, charts, and graphs.  The rules for an appropriate citation to this material is discussed in greater detail in elsewhere in this guide at "Pages, paragraphs, and pincites".

Internal cross-references begin with the signal "See." 

"Supra" is used to cite prior material while "infra" is used to cite subsequent material. Exact wording for internal cross-references, however, is flexible.  Both terms must be written in italics but they may be used either as an introductory signal combined with "See" or in a textual phrase directing the reader to the specific material.

Some examples of permissible uses of internal cross-reference citations follow:

See supra notes 35-38 and accompanying text.

See cases cited infra note 121.

See discussion supra Part III.A.

See supra pp. 94-97.

See infra Figure 5.