An internal citation in legal writing is a compact reference placed inside the body of your text that points a reader to the exact source, and usually the exact page, supporting a legal claim. Under the Bluebook, the dominant citation manual in American practice, each type of authority has its own format built from a short list of identifiers in a fixed order. Get the identifiers and punctuation right and the citation works. Get them wrong and the reader cannot find what you cited.
What follows is how to build citations for the sources you will encounter most often, how to signal the strength of each one, and how to shorten them once a source has already appeared.
How to Cite a Case
A case citation has five parts, all drawn from the first page of the opinion: the party names, the volume number, the reporter abbreviation, the starting page, and a parenthetical with the year and (where needed) the court.
A finished Supreme Court citation looks like this:
Fitzpatrick v. Bitzer, 427 U.S. 445 (1976).
The party names are italicized. A comma separates them from the volume number. The reporter abbreviation follows the volume, and the starting page follows the reporter with no punctuation between them. The year sits in parentheses at the end. Because “U.S.” identifies the Supreme Court, no court abbreviation appears inside the parenthetical. For lower federal courts the court goes in with the year:
Smith v. Jones, 850 F.3d 200 (5th Cir. 2017).
If the citation stands alone as its own sentence, put a period after the closing parenthesis. If it sits mid-sentence, a comma or semicolon joins it to the surrounding text.
Pinpoint Citations
Most of the time, pointing at a case is not enough. You need to land the reader on the specific page where the holding, rule, or quotation appears. That is the pinpoint.
Place a comma after the starting page, then the pinpoint page. If the opinion starts on 445 and the passage you need is on 452:
Fitzpatrick v. Bitzer, 427 U.S. 445, 452 (1976).
When a quotation runs across more than one page, give both pages separated by an en dash (452–53). Every factual or legal assertion tied to a particular passage in a source should carry a pinpoint. Trial courts expect this because a judge reading a brief wants to flip directly to the language.
Statutes and Constitutions
Statutes
A statutory citation gives the title number, the code abbreviation, and the section. For a federal statute:
42 U.S.C. § 1983.
A year in parentheses can follow when you need to anchor the citation to a specific edition of the code, which matters when a statute has been amended and you are referencing the version in force at a particular time. State statutes follow the same logic using the state code’s abbreviation, and the arrangement of title, chapter, and section varies by jurisdiction, so check the Bluebook’s jurisdiction tables.
Constitutions
Constitutional citations are short. Give the jurisdiction, the abbreviation “Const.,” and the subdivision. Nothing is italicized, and no date is needed unless the provision is no longer in effect.
- U.S. Const. art. I, § 3, cl. 1
- U.S. Const. amend. XIV, § 1
- N.Y. Const. art. VI, § 7
No punctuation separates the jurisdiction from the first subdivision. Commas separate successive parts.
Regulations, the Federal Register, and Court Rules
Code of Federal Regulations
Federal regulations use the statutory pattern. Title, “C.F.R.,” section:
1 C.F.R. § 10.2.
A year in parentheses can follow when the edition matters.
Federal Register
Proposed rules, notices, and other documents not yet codified appear in the Federal Register. Give the document title, the volume number, “Fed. Reg.,” the starting page, and the date in parentheses. Page numbers in the Federal Register never carry commas, even in the thousands.
Meeting Notice, 65 Fed. Reg. 3415 (Jan. 21, 2000).
For a proposed rule, add a second parenthetical with the status and intended codification location, such as “(proposed Mar. 7, 1991) (to be codified at 40 C.F.R. pt. 86).”
Federal Court Rules
Court rules are cited by the rule set and rule number, with no date when you are citing the version currently in effect:
- Fed. R. Civ. P. 12(b)(6)
- Fed. R. Evid. 702
Introductory Signals
Not every source you cite directly states the proposition in your text. Introductory signals are short words that tell the reader exactly how much support the source provides.
No signal means the source directly states the proposition, is the source of a quotation, or is the authority the text explicitly identifies. That is the strongest form of support. Once the support becomes indirect, a signal flags the gap:
- See indicates the source clearly supports the proposition, but indirectly. A reader checking it would agree the source backs the claim even though it does not use those exact words.
- See also is a step down. The source supports the point less directly or less forcefully, and an explanatory parenthetical helps the reader see why you included it.
- Cf. means the source supports an analogous proposition, not the one you are making. Without a parenthetical explaining the comparison, cf. gives the reader little to work with.
Signals are italicized. The exception is when a signal works as the verb of a sentence, in which case it appears in regular type. The signal e.g. takes a comma after it and can combine with others (see, e.g.,) to show that the cited source is one of several supporting the point.
String Citations
When more than one authority supports the same proposition, those citations form a string separated by semicolons:
Smith v. Jones, 500 U.S. 100, 105 (1991); Brown v. Green, 480 U.S. 50, 55 (1987).
Order matters. Authorities preceded by the same signal are arranged by their relative weight within the relevant jurisdiction, with the most authoritative or most recent first. If your writing concerns a particular state’s law, that state’s constitution, statutes, cases, and regulations generally precede authorities from other jurisdictions. Signals of different types (supportive, comparative, contradictory, background) should not be mixed inside a single citation sentence. Separate them with a period and start a new citation sentence for each signal type.
Short Forms for Repeated Sources
Once a source has appeared in full, repeating the entire citation every time clutters the analysis. Short forms replace the full citation, and the right short form depends on how recently the source appeared and what type of authority it is.
Id.
“Id.” is the shortest short form. Use it when citing the immediately preceding authority, and only when that preceding citation contains a single source. The abbreviation is italicized, period included. If the reference points to a different page in the same source, add “at” and the new page: Id. at 452. The moment another source intervenes, “id.” is off the table.
Case Short Forms
When an intervening citation has broken the chain, a short form built from the case name takes over. All versions carry a pinpoint preceded by “at”:
- Universal City Studios, Inc. v. Corley, 273 F.3d at 435
- Corley, 273 F.3d at 435
- 273 F.3d at 435
The one-party form is the most common in practice. Use whichever version a reader who saw the full citation earlier will recognize immediately.
Supra and Hereinafter
“Supra” is a short form for non-case sources: books, reports, legislative hearings, periodicals. It is not used for cases, statutes, constitutions, or regulations, unless the authority’s name is so long that repeating it would be unreasonable.
“Hereinafter” establishes a nickname for a source with a cumbersome title. Introduce the nickname in brackets at the first full citation, then use it in later “supra” references. This is most useful for government reports, lengthy titles, and sources by institutional authors whose names would otherwise consume an entire line.
Secondary Sources and Online Materials
Law Review and Journal Articles
A citation to a consecutively paginated journal runs: author, article title in italics, volume number, abbreviated journal name, first page, pinpoint (if any), and year in parentheses. Journal names are abbreviated using the Bluebook’s tables. Volume numbers are always Arabic numerals, even when the original source uses Roman. Issue numbers are not included.
With two authors, join the names with an ampersand. With three or more, either list all authors or give the first followed by “et al.”
Non-consecutively paginated publications like magazines and newspapers follow a slightly different pattern: author, article title in italics, periodical name, cover date, the word “at,” and the first page of the piece.
Internet Sources
When the source exists only online, or you accessed it electronically, place the URL at the end of the citation. If the URL is extremely long or full of non-textual characters, cite the root URL and add a parenthetical explaining how to navigate to the specific page.
Dates need attention. Use the date on the page if one appears. If the page shows only a “last updated” date, put that in a parenthetical. If no date exists at all, include your last-visited date formatted as “(last visited [date]).” Remove any automatic hyperlinks so the URL appears as plain text.
Practitioners’ Format vs. Academic Format
One boundary worth knowing before you format anything: the Bluebook has two parallel systems. Court documents and legal memoranda follow the “Bluepages” rules, which use only two typefaces, ordinary type and italics. Law review footnotes follow the main body of the Bluebook, which adds large and small capitals as a third typeface for certain sources like book titles and journal names. A citation formatted correctly for a brief may look wrong in a law review article, and the reverse, even though the underlying information is identical.
For a brief, motion, or memo, use the Bluepages. For a law review or academic piece, use the main body of the Bluebook. Mixing the two systems in the same document is a mistake editors catch at once.