Citing Subsequent History in Case Citations: Format and Abbreviations

When you cite a case in full under Bluebook Rule 10.7, you must append its complete subsequent history — every appellate action taken on that decision — using an italicized explanatory phrase like aff’d or rev’d, followed by the reporter information and a court-date parenthetical for the reviewing court.¹ Citing subsequent history in case citations tells the reader whether the authority you’re relying on still stands, and getting it right is a matter of a few abbreviations and a short list of exceptions.

When You Have to Include It

The obligation is triggered by full citations. Every time you cite a decision in full, the entire subsequent history goes with it.¹ If a federal district court decision was appealed and the circuit reversed it, your citation must show the reversal. If the Supreme Court later denied certiorari, that denial belongs there too, subject to the exceptions below. The outcome doesn’t matter for the rule to apply. An affirmance carries as much weight as a reversal because it tells the reader the decision survived challenge.

Short forms are different. When you refer back to the same case using id. or a shortened case name, you do not repeat the subsequent history. The reader has already seen it once.

What You Can Leave Out

Rule 10.7 carves out several categories of history that would clutter a citation without adding value:

Certiorari denials more than two years old. Include a denial only if the case was decided within the past two years, or if the denial itself is directly relevant to your point.¹
History on remand. When a higher court sends a case back for further proceedings, leave the remand out unless it matters to the legal point.¹
Rehearing denials. A court’s refusal to rehear is omitted unless relevant to your argument.
Withdrawn dispositions. If a court affirmed and then reversed itself on rehearing, the withdrawn affirmance should not appear.¹
Reversals on unrelated grounds. If the subsequent court reversed or modified the decision on an issue unrelated to the proposition you’re citing, you may omit that history. A reversal on a procedural point that leaves the substantive holding intact doesn’t need to appear when you’re citing the substantive rule.

The Abbreviations

Subsequent history uses italicized explanatory phrases from Bluebook Table T8.² The ones you’ll use most often:

aff’d — affirmed by the higher court
rev’d — reversed by the higher court
vacated — voided entirely by the higher court
cert. denied — the Supreme Court or other high court declined review
cert. granted — the court agreed to hear the appeal
reh’g denied — the court refused to reconsider
modified — the higher court changed part of the decision
rev’d on other grounds — reversed for reasons unrelated to the cited proposition

Watch the tense. The past-tense forms (aff’d, rev’d) tell the reader that a higher court acted on the cited case. The present-participle forms (aff’g, rev’g) mean the cited decision was itself acting on a lower court’s ruling. That distinction matters when you’re combining subsequent history with prior history in the same string.

How the Citation String Fits Together

Subsequent history attaches to the end of the full citation, separated by a comma. The explanatory phrase is italicized, and the subsequent decision gets its own reporter information and a court-date parenthetical:

Cent. Ill. Pub. Serv. Co. v. Westervelt, 342 N.E.2d 463 (Ill. App. Ct. 1976), aff’d, 367 N.E.2d 661 (Ill. 1977).

For United States Supreme Court decisions, only the year goes in the parenthetical because the reporter identifies the court. Federal circuit decisions use the circuit abbreviation and year, such as (5th Cir. 2023). State courts follow the conventions in Bluebook Table T1.

Multiple Subsequent Actions

When a case has more than one subsequent event, list them chronologically, separating each with a comma. A district court decision affirmed by the circuit and then hit with a denial of certiorari looks like this:

Smith v. Jones, 200 F. Supp. 2d 500 (E.D. Va. 2002), aff’d, 350 F.3d 400 (4th Cir. 2003), cert. denied, 541 U.S. 1000 (2004).

Each step gets its own abbreviation, reporter information, and parenthetical.

Where Other Parentheticals Go

An explanatory parenthetical about the primary case — a note about the holding or a concurrence — comes before the subsequent history. Subsequent history is always last in the citation string.¹ Designations like en banc or per curiam also precede it.

When the Case Name Changes on Appeal

A case sometimes carries a different name on appeal. The trial defendant may become the petitioner before the Supreme Court, or a government agency may substitute for a named official. When that happens, flag the new name with sub nom. (short for sub nomine, “under the name of”):

Great W. United Corp. v. Kidwell, 577 F.2d 1256 (5th Cir. 1978), rev’d sub nom. Leroy v. Great W. United Corp., 443 U.S. 173 (1979).

Both sub nom. and the new case name are italicized as part of the explanatory phrase.

Three situations do not require sub nom. even when the caption looks different:³

The parties are simply reversed. If Smith v. Jones becomes Jones v. Smith, you don’t note the switch.
The subsequent history is only a denial of certiorari or rehearing. Omit the new case name in that situation.
Only the government party’s name changes in an administrative appeal while the private party’s name stays constant. The unchanged private party name is enough.

Prior History Works the Other Direction

Prior history records what happened before the decision you’re citing. It’s optional in most situations under the Bluebook, included only when the lower court proceedings matter to your point or when the cited opinion is too brief to describe the issues adequately on its own.

When a citation includes both, prior history comes first, immediately after the primary citation, with subsequent history following. Prior history uses the present-participle forms (aff’g, rev’g) because the cited decision is the one doing the affirming or reversing. Subsequent history uses the past-tense forms (aff’d, rev’d) because a later court acted on the cited decision.

Errors That Hurt Your Credibility

The most damaging mistake is omitting a reversal or vacatur. Citing a case as good law after a higher court struck it down erodes your credibility with the court and, in extreme cases, can trigger sanctions. Running the case through Shepard’s or KeyCite before you finalize a brief is the only reliable safeguard.

The opposite mistake is including too much. A decade-old certiorari denial, irrelevant remand proceedings, and a rehearing denial that changes nothing create noise. The Rule 10.7 exceptions are there to be used. A clean citation that carries only the relevant history reads more persuasively than an exhaustive one that buries the signal.

Formatting slips are the easiest to catch and the most often missed. The explanatory phrase must be italicized. A comma must separate the primary citation from the subsequent history. Each subsequent action needs its own reporter information and court-date parenthetical. Missing any of these creates ambiguity about where the primary citation ends and the history begins.¹

1
The Bluebook Online. Rule 10.7 Prior and Subsequent History
2
The Bluebook Online. Table T8 Explanatory Phrases
3
Office of the Solicitor General. Office of the Solicitor General Citation Manual