Parallel Citations Explained: When and How to Use Them
A parallel citation provides two or more reporter references for the same case. While the Bluebook generally requires only one reporter, many state courts and some legal writing contexts demand parallel citations. This guide explains when they are required, how to format them, and which states still use them.
What Are Parallel Citations?
A parallel citation is a reference to the same judicial opinion in two or more reporter series. The same case often appears in multiple reporters — for example, a New York Court of Appeals decision might be printed in the official New York Reports (N.Y.3d), the regional North Eastern Reporter (N.E.3d), and the New York Supplement (N.Y.S.3d). A parallel citation lists two or more of these references so that the reader can locate the case in whichever reporter they have access to.
Example: Parallel citation for a New York case
Palsgraf v. Long Island R.R. Co., 248 N.Y. 339, 162 N.E. 99 (1928).
In this example, 248 N.Y. 339 is the citation to the official New York Reports, and 162 N.E. 99 is the citation to the North Eastern Reporter. Both refer to the same opinion. The comma between them signals that these are parallel citations, not citations to different cases.
When Are Parallel Citations Required?
The answer depends on the context. The Bluebook and court rules treat parallel citations differently:
In academic writing (law review footnotes)
The Bluebook generally requires only one reporter citation — the preferred reporter listed in Table T1 for that jurisdiction. Parallel citations are not required and are typically omitted to save space.
In court filings (briefs and memoranda)
Many state courts require parallel citations in documents filed with the court. Check the local rules of the specific court. The Bluebook's Bluepages (the practitioner section) provides guidance on when parallel citations are expected in court documents.
In legal writing courses
Follow your professor's instructions. Some professors teach the academic Bluebook style (no parallel citations), while others teach the practitioner style (parallel citations for in-state cases).
The key rule of thumb: if you are writing for a court in a state that publishes an official reporter, check whether that court's rules require you to include the official citation alongside the unofficial one.
The General Rule: Cite to One Reporter
The Bluebook's default rule, found in Rule 10.3.1, is to cite to only one reporter. The preferred reporter for each jurisdiction is listed in Table T1. For most federal cases, this is straightforward:
U.S. Supreme Court — cite to U.S. Reports
Brown v. Bd. of Educ., 347 U.S. 483 (1954).
Federal circuit court — cite to F.3d or F.4th
United States v. Jones, 565 F.3d 1234 (9th Cir. 2019).
Federal district court — cite to F. Supp. 3d
Smith v. City of New York, 450 F. Supp. 3d 234 (S.D.N.Y. 2020).
For U.S. Supreme Court cases, the Bluebook strongly prefers the official U.S. Reports. Do not cite to the Supreme Court Reporter (S. Ct.) or the Lawyers' Edition (L. Ed.) unless the case has not yet appeared in the U.S. Reports. Never provide parallel citations for Supreme Court cases in academic writing.
Exceptions: When to Include Parallel Citations
There are several situations where parallel citations are appropriate or required:
State court rules require it
Many states require parallel citations when citing that state's cases in documents filed with its courts. New York, California, Illinois, and Ohio are among the most notable examples.
The official reporter is hard to access
If the official reporter for a jurisdiction is not widely available, providing a parallel citation to a regional reporter (N.E.2d, P.3d, etc.) helps readers locate the case.
Your professor or law review requires it
Some legal writing professors and law reviews have their own style guides that require parallel citations for state cases, especially for the state where the law school is located.
Citing a case from another jurisdiction's court documents
The Bluepages (practitioner section) of the Bluebook recommend providing a parallel citation when the case might be difficult for the court to locate using only one reporter.
Format for Parallel Citations
When including parallel citations, the format follows a specific order and punctuation pattern:
Case Name, [Official Reporter], [Regional Reporter], [State-specific Reporter] (Court Year).
The official reporter always comes first, followed by the regional reporter, followed by any state-specific reporter. Each reporter citation is separated by a comma. The court and year parenthetical appears only once, at the end.
Two reporters
Palsgraf v. Long Island R.R. Co., 248 N.Y. 339, 162 N.E. 99 (1928).
Three reporters
People v. LaValle, 3 N.Y.3d 88, 817 N.E.2d 341, 783 N.Y.S.2d 485 (2004).
With pinpoint pages
Palsgraf v. Long Island R.R. Co., 248 N.Y. 339, 341, 162 N.E. 99, 100 (1928).
When including pinpoint citations with parallel references, provide the pinpoint page for each reporter. The pinpoint follows the first page of the case in each reporter, separated by a comma. This allows the reader to find the exact passage in whichever reporter they are using.
When the official reporter citation is provided, the court abbreviation in the parenthetical may be omitted if the reporter itself identifies the court. For example, "N.Y." already tells the reader this is the New York Court of Appeals, so the parenthetical needs only the year: (1928).
Examples by State
Here are parallel citation formats for some of the states where they are most commonly required or used:
New York courts require parallel citations in all court filings. The official reporter (N.Y.3d for the Court of Appeals, A.D.3d for the Appellate Division) is listed first, followed by the regional reporter (N.E.3d or N.E.2d) and the New York Supplement (N.Y.S.3d).
Court of Appeals
People v. Cahill, 2 N.Y.3d 14, 809 N.E.2d 561, 777 N.Y.S.2d 332 (2003).
Appellate Division
Smith v. Jones, 150 A.D.3d 456, 55 N.Y.S.3d 12 (1st Dep’t 2017).
California courts require parallel citations to the official California Reports (Cal.5th, Cal.App.5th) and the Pacific Reporter (P.3d). The California Style Manual provides additional guidance that sometimes differs from the Bluebook.
Supreme Court
In re Marriage Cases, 43 Cal. 4th 757, 183 P.3d 384 (2008).
Court of Appeal
Doe v. Roman Catholic Archbishop, 45 Cal. App. 5th 1, 258 Cal. Rptr. 3d 345 (2020).
Illinois adopted a public domain citation format in 2011. Cases decided after July 1, 2011, use a court-assigned citation that does not depend on any reporter. Older cases use the traditional parallel citation format with the official Illinois Reports and the North Eastern Reporter.
Post-2011 (public domain format)
People v. Taylor, 2023 IL 128316, ¶ 15.
Pre-2011 (traditional parallel cite)
People v. Caballes, 221 Ill. 2d 282, 851 N.E.2d 26 (2006).
Ohio adopted a vendor-neutral public domain citation system. Decisions from 2002 onward use a court-assigned number. Parallel citations to the North Eastern Reporter are commonly included but not always required. When filing in Ohio courts, check the Ohio Supreme Court's Writing Manual for current requirements.
Post-2002 (public domain with parallel)
State v. Bodyke, 2010-Ohio-2424, 933 N.E.2d 753.
Pre-2002 (traditional)
State v. Maupin, 42 Ohio St. 2d 473, 330 N.E.2d 708 (1975).
Star Pagination and Public Domain Citations
Star pagination is the system used by Westlaw and Lexis to indicate where page breaks from other reporters fall within their text. When you are reading a case on Westlaw and see an asterisk followed by a number (e.g., *341), that tells you where page 341 of the official reporter begins. This is useful when you need to provide a pinpoint citation to the official reporter but are reading the case on Westlaw.
Public domain citations, also called vendor-neutral or medium-neutral citations, are assigned by the court itself and do not depend on any particular reporter or database. These use the year, the court abbreviation, and a sequential case number. Several states have adopted public domain citation systems, including Illinois, Ohio, Oklahoma, Louisiana, and others.
Public domain citation (Illinois)
People v. Williams, 2022 IL App (1st) 200567, ¶ 23.
Public domain citation (Oklahoma)
Bosh v. Cherokee Cty. Bldg. Auth., 2013 OK 9, ¶ 12.
Public domain citation (Louisiana)
State v. Draughn, 2005-1825 (La. 1/17/07); 950 So. 2d 583, 591.
Public domain citations use paragraph numbers (¶) instead of page numbers for pinpoint references, since the paragraph numbering is consistent regardless of the format in which the opinion is read. When a state has adopted a public domain format, the Bluebook requires you to use it as the primary citation, with a parallel reporter citation if required by local rules.
Practical Tips for Law Students
Check Table T1 first
The Bluebook's Table T1 lists the preferred reporter for every jurisdiction. When in doubt about whether to include a parallel citation, start there. It will tell you which reporter to cite in academic work.
Know your jurisdiction's local rules
If your legal writing class involves drafting court documents, find out whether the target court requires parallel citations. This varies by state and sometimes by court level within a state.
Official reporter always comes first
When providing parallel citations, always list the official reporter before the unofficial reporter. The official reporter is the one published by or under the authority of the state government.
Provide pinpoints for each reporter
If you are citing to a specific page within the opinion and providing parallel citations, include the pinpoint page for each reporter. This helps readers using different reporters find the exact passage.
Use Westlaw or Lexis to find parallel citations
Both major databases display parallel citations for published cases. On Westlaw, look for the "Parallel Citations" field. On Lexis, check the case header. This saves time compared to manually searching each reporter.
Do not provide parallel citations for federal cases
Federal cases published in the Federal Reporter, Federal Supplement, or U.S. Reports do not need parallel citations. These reporters are universally available and there is no official/unofficial distinction in the federal system.