String citation rules come from the Bluebook (22nd edition), and they govern three things at once: the order the authorities appear in, the signal that introduces each one, and the punctuation that holds the string together. Get those three right and the citation does its job; get any of them wrong and the string either misstates the law or looks like filler.
Order of Authorities
Rule 1.4 tells writers to arrange authorities “in a logical manner,” leading with the source most directly on point. In practice that means ordering by type of authority first, then by jurisdiction, then by hierarchy or date. The 22nd edition gives more flexibility than earlier editions, but the traditional sequence is still what most courts and journals expect.
The conventional order runs top to bottom like this:
- Constitutions, with the U.S. Constitution before any state constitution.
- Statutes, with federal statutes from the U.S. Code before state statutes.
- Cases, with federal decisions before state decisions.
- Legislative materials such as committee reports and hearing transcripts.
- Administrative and executive materials, including federal regulations, executive orders, and agency guidance.
- Secondary sources: treatises, law review articles, restatements, and other commentary.
Constitutions lead because nothing outranks them on a point they address directly. Federal statutes come next because the Supremacy Clause makes them override conflicting state law.1Legal Information Institute. Wex – Order of Authorities
Ordering Cases Within the String
Inside the case block, federal cases come before state cases. Federal cases follow their own ladder: U.S. Supreme Court first, then Courts of Appeals, then District Courts. When you have two cases from the same court, list the most recent first and work backward — a 2024 Seventh Circuit decision precedes a 2019 Seventh Circuit decision.1Legal Information Institute. Wex – Order of Authorities
State decisions follow all federal ones. Different states are arranged alphabetically by state name, and within one state, the highest court leads, then intermediate appellate courts, then trial courts. So an Alabama Supreme Court case precedes an Alaska Court of Appeals case, and both precede anything from California.1Legal Information Institute. Wex – Order of Authorities
Introductory Signals
A signal is the short word or phrase at the front of a citation telling the reader how that source relates to the proposition. Rule 1.2 sorts signals into four families: support, comparison, contradiction, and background. A wrong signal misrepresents what the authority actually holds, so the choice is substantive, not cosmetic.
Signals That Show Support
The split that trips up the most writers is between no signal and “See.” No signal is the correct choice when the cited authority directly states the proposition, identifies the source of a quotation, or is the authority named in the text. “See” is for authorities that clearly support the proposition but require one inferential step. Writers routinely use “See” where no signal is correct, which weakens the citation by implying the case says less than it does.
The other supportive signals each do something specific. “E.g.” marks the cited source as one of many that stand for the point, and it combines with other signals as in “See, e.g.,” “Accord” signals that another authority directly states the proposition and the cited source agrees. “See also” adds further support once a point has already been established by an earlier citation. “Cf.” flags support by analogy rather than directly on point.2The Bluebook. Bluebook Rule 1.2 – Introductory Signals
Comparison, Contradiction, and Background
“Compare … with …” is the only comparison signal. Parenthetical explanations are usually essential, because without them the comparison has no payoff for the reader.
The contradiction signals mirror the supportive ones. “Contra” means the cited authority directly states the opposite. “But see” means it clearly supports the contrary position. “But cf.” means it supports the contrary position by analogy. The word “but” marks the shift from supportive to contradictory authorities and drops out when one negative signal follows another.3Legal Information Institute. Basic Legal Citation – Signals
“See generally” is the lone background signal. It points to helpful context or broader treatment of the topic without claiming the source supports or contradicts the specific proposition.
Signal Order When You Combine Them
When a string uses more than one signal, Rule 1.3 fixes the order: supportive signals first, then comparison, then contradiction, then background. A “See” citation always precedes a “See also” citation, and both precede “But see” or “Contra.” Authorities that share a signal are grouped together and separated by semicolons. When the string moves from one signal family to another, that transition closes the citation sentence with a period and starts a new one.4The Bluebook. Bluebook Rule 1.3 – Order of Signals
Punctuation and Formatting
Most string citations are citation sentences: they stand alone, start with a capital letter or a capitalized signal, and end with a period. Within that sentence, a semicolon separates every full citation from the next, whether the next source is the same type (another case) or different (a statute after a case). One period closes the whole string.5Legal Information Institute. Basic Legal Citation – Section 6-400 Order
The exception involves signal transitions. Signals in the same family stay in the same citation sentence. When you shift from supportive to contradictory signals, the supportive group ends with a period and the contradictory signal opens a new citation sentence.
Parentheticals
An explanatory parenthetical follows the citation it describes and sits before the semicolon separating that citation from the next. A parenthetical like “(holding that warrantless searches of cell phones violate the Fourth Amendment)” goes after the year of the case and before the semicolon leading to the next source. In a long string, parentheticals do the real work: they let the reader see what each authority contributes without pulling every case.
Pinpoint Citations
Each authority in a string gets its own pinpoint when you are citing a specific passage rather than the whole source. The pinpoint follows the starting page, separated by a comma. In a string the pattern is: Case Name, volume Reporter startpage, pinpoint (Year); Next Case, volume Reporter startpage, pinpoint (Year). Dropping pinpoints across a string suggests the writer listed authorities without reading them.
Formatting Each Entry
Every citation inside the string still has to be correct on its own before the semicolon links it to the next. Case names are italicized, the volume number precedes the reporter abbreviation, and the starting page follows the reporter. Statutes use their standard title-code-section format. Inconsistency across entries is what makes a citation block look sloppy even when the order is right.
The “Id.” Restriction After a String
You cannot use “Id.” to point back to an authority that appeared inside a string citation. The short form “Id.” works only when the immediately preceding citation contains a single authority, because a string by definition contains more than one and “Id.” becomes ambiguous. To refer back to one of the sources in the string, use that source’s own short form (a case-name short form or “supra”) instead.6The Bluebook. Bluebook Rule 4.1 – Id
Where Secondary Sources Sit
Secondary materials come last, after every constitution, statute, case, piece of legislative history, and administrative source. The Bluebook sets its own internal order within the secondary block:1Legal Information Institute. Wex – Order of Authorities
- Restatements and model codes, with the most recent version first.
- Books and treatises, alphabetically by author’s last name.
- Law review articles, with non-student work before student-written work, each group alphabetical by author.
- Magazine and newspaper articles, alphabetically by author, or by title if no author is named.
- Electronic sources and internet materials, at the bottom, alphabetically by author or title.
Internet sources ranking low does not mean they cannot appear in a string, but they never lead one that also contains cases or statutes. A blog post cited alongside a Supreme Court opinion goes at the end, and a parenthetical explaining why it is there is usually warranted.
When to Use a String at All
The format pays off when you need to show that a rule is well-settled across jurisdictions, or when you are mapping a split and want the reader to see both sides. One citation shows a judge that one court agrees with you; a string of four or five shows that your reading is the weight of authority. For a law review article surveying how different jurisdictions handle a doctrine, strings are close to expected.
They are the wrong tool for uncontested propositions. If the point is not in dispute, one well-chosen authority from the controlling court does the job, and piling on more citations hides your analysis rather than reinforcing it. Before filing, check the local rules and the assigned judge’s standing orders: some courts discourage long strings for routine points, and a technically correct citation that irritates the court reading it costs more than it gains.