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BlueJayBook: Textual v. Citation Sentences

This Guide presents Bluebook exercises and instructions that are used in Creighton Law School Legal Research & Writing classes.

Textual v. Citation Sentences

I. Abbreviations in Case Names.

A. Rule 10.2.1: In textual sentences, abbreviate widely know acronyms and the eight words specified in Rule 10.2.1(c) ONLY:

&, Ass’n, Bros., Co., Corp., Inc., Ltd., No.

In Western Utilities & Transportation Co. v. Lakewood Refining, Inc., 450 U.S. 24, 27 (1990), the Court held that punitive damages are recoverable for fraud.

B. Rule 10.2.2: In citation sentences, abbreviate the same eight words and any other words you find listed in Table 6. Add an “s” to abbreviations to make them plural unless otherwise instructed in Table 6.

Punitive damages are recoverable in fraud actions. W. Utils. & Transp. Co. v. Lakewood Ref., Inc., 450 U.S. 24, 27 (1990).

C. Rule 10.2.2: Also, abbreviate geographical units according to Table 10 unless the geographical unit is the entire name of the party. This includes United States.

II. Citations in Textual Sentences or Citation Sentences: Which is Best?

A. Full Citation Form: A full citation works well in a textual sentence as well as a citation sentence.

1. If the emphasis of your sentence is the case itself, make it the object (noun) of your sentence (place the citation in the textual sentence):

The court in Scott v. Scott, 240 Pa. Super. 65, 67, 368 A.2d 288, 289 (1976), explained that partial custody refers to the right to take possession of a child away from the custodial person for a specified period of time.

2. However, if the emphasis of your sentence is the rule of the case, place the citation at the end of the textual sentence as a free-standing citation sentence:

Partial custody refers to the right to take possession of a child away from the custodial person for a specified period of time. Scott v. Scott, 240 Pa. Super. 65, 67, 368 A.2d 288, 289 (1976).

B. Short Form (Rule 10.9).:

1. Avoid using a short form in a textual sentence:

Very awkward; don’t do this: Poukner, 556 So. 2d at 1232, held that a defendant must object to the sufficiency of the trial court's findings regarding the admissibility of child-hearsay statements in order to raise the legal error on appeal.

Never use Id. in a textual sentence: According to id., persons who are not a child's parent or legal guardian may be proper parties to a custody proceeding.

2. The use of short forms in citation sentences:

a. Full citation: the first time a case is cited, it must be cited fully. Only after this can a short form be used.

In all child custody cases, the welfare of the child and the child's best interest is the “primary, paramount and controlling consideration of the court.” Cook v. Cobb, 271 S.C. 136, 140, 245 S.E.2d 612, 614 (1978).

b. After a case is cited (whether fully or using a short form), use a form of Id., unless there is an intervening authority cited (some other authority between the first citation and the Id.). In this example, the citation (using Id.) is to the exact pages as in the earlier cite.

In all child custody cases, the welfare of the child and the child's best interest is the “primary, paramount and controlling consideration of the court.” Cook v. Cobb, 271 S.C. 136, 140, 245 S.E.2d 612, 614 (1978). In certain circumstances, persons who are not a child's parent or legal guardian may be proper parties to a custody proceeding. Id.

c. What if you are using Id. but the pages have changed?

In all child custody cases, the welfare of the child and the child's best interest is the “primary, paramount and controlling consideration of the court.” Cook v. Cobb, 271 S.C. 136, 140, 245 S.E.2d 612, 614 (1978). In certain circumstances, persons who are not a child's parent or legal guardian may be proper parties to a custody proceeding. Id. at 141, 245 S.E.2d at 615.

d. Short form with a party name (when you cannot use a form of Id. and the party name is not used in the textual sentence):

The court held that a defendant must object to the sufficiency of the trial court's findings regarding the admissibility of child-hearsay statements in order to raise the legal error on appeal. Poukner, 556 So. 2d at 1232.

e. Short form without a party name (when you cannot use a form of Id. and the party name is used in the textual sentence):

The court in Poukner held that a defendant must object to the sufficiency of the trial court's findings regarding the admissibility of child-hearsay statements in order to raise the legal error on appeal. 556 So. 2d at 1232.


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