Part 7 of the Legal Methods Lecture SeriesBy Deborah Gordon

String Cites - IntroductionWhat is a string citation?

A list of multiple authorities in a single citation sentence. When do you use a string cite?

When you synthesize a rule from more than one sourceWhen you refer in your analysis to information from more

than one authority

Parallel Citations - IntroductionParallel citations are citations to more than one source

(most frequently, more than one case reporter) for the same authority.

Consult the jurisdiction’s local rules to determine whether parallel cites are required.

When to use string cites?Synthesizing sourcesDocumenting a jurisdictional splitWhat about multiple cites for a single proposition?

Formalities of a String CitePunctuation: use semicolons to separate authorities in a

string cite.Short form: use the full citation the first time a source is

mentioned and the short form thereafter.

Use of “Id.” in String CitesYou may use the short form “id.” to begin a string cite

when:You are referring to the immediately preceding cite; andThat cite refers to just one source.Example:

The sky is blue. Smith v. Brown, 25 U.S. 18 , 22 (1901). When the sky is blue, rain is unlikely. Id. at 23; Setting Sun Ass’n v. Rain Clouds, Inc., 244 F.3d 718, 727 (2d Cir. 2009).

Never use “id.” to refer to a string cite or to any source within a string cite, even the final one.

How to Order Authorities Within a String Cite:Begin with any authority that is substantially more

helpful or authoritative than the others (if there is one). If no clear governing authority exists, use the order

provided in Bluebook Rule 1.4.

Order of Authorities: General RulesGeneral order:

Constitutions (and foundational documents) StatutesTreatiesCasesOther materials (legislative, secondary sources, etc.)

In general, citations within each category are:Federal, state, foreign, internationalAlphabeticalHierarchicalReverse chronological order

Order of Authorities: CasesBluebook Rule 1.4(d)Cite cases in the following order:

(1) federal(2) state(3) foreign(4) international

Cases decided by the same court are arranged in reverse chronological order.

Order of Authority: Federal CasesThe most common federal cases are cited in the

following order:Supreme CourtCourts of appealsCourt of Claims, special Appeals courts (bankruptcy,

patents) district courtsdistrict bankruptcy courts Court of federal claims and tax courtadministrative agencies (alphabetically by agency)

Order of Authority: State CasesAfter all federal cases are cited, state cases may be

cited as follows:Alphabetically by state Then by rank within each state and Then in reverse chronological order within each of the

same ranked courtsExample:

See, e.g., Mitchell v. Davis, 598 So. 2d 801, 803 (Ala. 1992); Robinson v. Robinson, 914 S.W.2d 292, 295 (Ark. 1996); Bercume v. Bercume, 704 N.E.2d 177, 180 (Mass. 1999); Schuler v. Schuler, 416 N.E.2d 197, 200 (Mass. 1981); Harris v. Harris, 500 N.E.2d 1359, 1362 (Mass. App. Ct. 1986).

Order of Authority: Other MaterialsRefer to Bluebook Rule 1.4 for how to order all other

materials, including legislative materials, briefs, and secondary sources.

You may change the order of authority within a string cite by using citation signals.

Parallel Cites - IntroductionParallel citations are citations to more than one

source (most frequently, more than one case reporter) for the same authority.

Example: Cotter v. Pelligrino, 567 Mass. 25, 31, 449 N.E.2d 12, 18 (1992).

Local RulesSome states do not publish their own reporters so

parallel cites are not needed.Some courts in states that publish their own

reporters require lawyers to provide parallel citations for each cited case decided by a court in that jurisdiction.

Some courts always require parallel cites.

If the Local Rules Require Parallel Cites: The two citations should be separated by a comma in

your citation sentence.Cite to the state reporter first, followed by the regional

reporter.Provide pinpoint cites for each reporter.

Example: Harris v. State, 222 Ga. App. 56, 61, 473 S.E.2d 229, 232 (Ct. App. 1996).

If the Local Rules Require Parallel Cites: If the state is obvious from the official reporter title, omit

the state abbreviation from the parentheses with the date.

Omit the name of the court from the parentheses if it is the highest court in the state.If the decision is from a lower state court, keep the

remaining court abbreviation in the parentheses.Example: Harris v. State, 222 Ga. App. 56, 61, 473 S.E.2d

229, 232 (Ct. App. 1996).

If the Local Rules Do Not Require Parallel Cites:Refer to Table 1 starting at page 198 in your Bluebook to

determine which reporter to cite.If only the regional reporter must be cited, provide the

abbreviation of the court in the parentheses.Example:

Parallel: Cotter v. Pelligrino, 567 Mass. 25, 31, 449 N.E.2d 12, 18 (1992).

No Parallel: Cotter v. Pelligrino, 449 N.E.2d 12, 18 (Mass. 1992).

Short Forms and Use of “Id.”Use short forms for both cites in the parallel citation. “Id.” replaces only the official (first, state) reporter.Examples:

Standard Short Form: Cotter, 567 Mass. at 31, 449 N.E.2d at 18.

Use of “Id.”: In Cotter, the court held that the sky is blue. Id., 449 N.E.2d at 18.