10 Common Bluebook Citation Mistakes Law Students Make
Bluebook citation looks simple until you get the details wrong. These ten mistakes appear in nearly every 1L legal writing class. Each one is easy to make and easy to fix once you know what to look for.
Mistake #1: Forgetting to Italicize Case Names
In academic legal writing (the format used in law school classes and law review articles), case names must be italicized. This includes the party names and the "v." between them. Forgetting to italicize is the single most common citation error in 1L papers.
Wrong
Miranda v. Arizona, 384 U.S. 436 (1966).
Correct
Miranda v. Arizona, 384 U.S. 436 (1966).
Note: In practitioner documents (briefs filed with courts), case names are underlined rather than italicized, depending on local rules. But in law school, default to italics unless your professor says otherwise.
Mistake #2: Including the Court for Supreme Court Cases
When citing a Supreme Court case to the United States Reports (U.S.), do not include the court name in the date parenthetical. The reporter itself identifies the court — only the U.S. Supreme Court is published in the U.S. Reports. Adding "U.S." or "S. Ct." in the parenthetical is redundant.
Wrong
Brown v. Bd. of Educ., 347 U.S. 483 (U.S. 1954).
Correct
Brown v. Bd. of Educ., 347 U.S. 483 (1954).
The same rule applies to any reporter that publishes opinions from only one court. For example, the N.Y. reporter publishes only New York Court of Appeals decisions, so you do not include the court name when citing to that reporter.
Mistake #3: Using Id. After Multiple Sources
Id. refers to the immediately preceding cited source. If the immediately preceding footnote or citation sentence cites more than one source, the reader cannot know which source Id. refers to. In that situation, you must use the short form citation instead.
Wrong
Footnote 5: Miranda, 384 U.S. at 444; Brown, 347 U.S. at 495.
Footnote 6: Id. at 450.
Correct
Footnote 5: Miranda, 384 U.S. at 444; Brown, 347 U.S. at 495.
Footnote 6: Miranda, 384 U.S. at 450.
Mistake #4: Wrong Reporter Abbreviations
The Bluebook requires exact reporter abbreviations, including specific spacing and periods. Getting these wrong is a common error, especially with reporters that look similar. Always consult Table T1.
Wrong
F3d (missing periods)
S.Ct. (missing space)
NE2d (missing periods)
F. 3d (extra space)
Correct
F.3d
S. Ct.
N.E.2d
F.3d
The spacing rule: close up adjacent single capitals (F.3d, N.E.2d), but use a space between elements where one is longer than a single capital (F. Supp., S. Ct., Cal. App.). This rule applies throughout the Bluebook.
Mistake #5: Missing Pinpoint Citations
A pinpoint citation directs the reader to the exact page that supports your proposition. Omitting it forces the reader to search through the entire opinion to find the relevant passage. This is both discourteous and unhelpful. Always include a pinpoint unless you are citing the case for its general holding.
Wrong (when citing a specific point)
Palsgraf v. Long Island R.R. Co., 248 N.Y. 339 (1928).
Correct
Palsgraf v. Long Island R.R. Co., 248 N.Y. 339, 341 (1928).
Mistake #6: Incorrect Short Form Format
The short form for a case citation includes one party name (typically the first non-governmental party), the volume and reporter, and the word "at" followed by the pinpoint page. Students often get the format wrong by including too much or too little information.
Wrong
Miranda v. Arizona at 450.
Miranda, 384 U.S. 436, 450.
Miranda, at 450.
Correct
Miranda, 384 U.S. at 450.
The pattern is: Party Name, Volume Reporter at Pinpoint. Note the comma after the party name, and the word "at" before the page number (not a comma). Do not repeat the first page of the opinion in the short form.
Mistake #7: Wrong Spacing in Reporter Names
The Bluebook's spacing rule for abbreviations is: close up adjacent single capitals, but leave a space when one element is longer than a single capital. This rule is the source of many errors because it is counterintuitive and requires checking each abbreviation.
Wrong
F. Supp.3d (missing space before 3d)
F. 3d (extra space)
N. E. 2d (extra spaces)
S.Ct. (missing space)
Correct
F. Supp. 3d
F.3d
N.E.2d
S. Ct.
Mistake #8: Failing to Abbreviate Party Names
In a citation sentence or clause (as opposed to a textual sentence), the Bluebook requires you to abbreviate words listed in Table T6. Common words like "Company," "Corporation," "Board," "University," and "Railroad" must all be abbreviated. Failing to abbreviate makes the citation look unprofessional.
Wrong
Brown v. Board of Education, 347 U.S. 483 (1954).
Correct
Brown v. Bd. of Educ., 347 U.S. 483 (1954).
Important exception: when the case name appears as part of a textual sentence (e.g., "In Brown v. Board of Education, the Court held..."), you only abbreviate widely known abbreviations and the eight specific words listed in Rule 10.2.1(c). In citation sentences and clauses, abbreviate all words in Table T6.
Mistake #9: Mixing Up Signals (See vs. See also vs. Cf.)
Citation signals tell the reader the relationship between your proposition and the cited authority. Using the wrong signal is worse than using no signal, because it misleads the reader about the strength of your support.
[No signal]
The cited authority directly states the proposition, is the source of a quotation, or identifies an authority referred to in the text.
See
The cited authority clearly supports the proposition, but does not directly state it. An inferential step is required.
See also
The cited authority provides additional support beyond the sources already cited.
Cf.
The cited authority supports a proposition different from the main proposition but sufficiently analogous to lend support.
But see
The cited authority clearly supports a proposition contrary to the main proposition.
The most common error is using see when no signal is needed. If the case directly states your proposition or is the source of a quotation, do not use any signal. Use see only when an inferential step is required.
Mistake #10: Forgetting Subsequent History
If the case you are citing was later reversed, vacated, overruled, or had certiorari denied (within two years), you must include that subsequent history in your citation. Omitting a reversal is particularly problematic because you would be citing authority that no longer stands.
Wrong (omitting reversal)
Doe v. Roe, 150 F.3d 800 (7th Cir. 2000).
Correct
Doe v. Roe, 150 F.3d 800 (7th Cir. 2000), rev'd, 530 U.S. 100 (2001).
The procedural history phrases (aff'd, rev'd, vacated, cert. denied) are italicized and follow the main citation after a comma. You may omit a denial of certiorari if the case is more than two years old, unless the denial is relevant to your argument.