Bluebook Short Form Citations Explained

A short form is a stripped-down citation that identifies a source you have already cited in full. The point is reader convenience: once you have given the reader everything needed to locate Brown v. Board of Education, repeating the full cite every time wastes space and signals that you do not know the rules.

The permission question turns on where you are writing. In law review footnotes, Rule 10.9 lets you use a case short form when the case has been cited in full in one of the preceding five footnotes; many journals treat that five-footnote window as a hard limit and will make you re-cite in full outside it. In briefs and memoranda, the Bluepages (B10.2) use a readability standard: use the short form if the full cite appears in the same general discussion and the reader will have no trouble identifying it. When in doubt, give the full cite again. Nobody has ever lost points for being too findable.

Rule numbers below track the 21st edition. Numbering occasionally shifts between editions, so check the edition your course requires before you rely on a specific number in a footnote.

Take one distinctive party name, keep the volume and reporter, drop the first page, and add "at" plus the pinpoint. Drop the court-and-date parenthetical and any prior or subsequent history.

Full: Brown v. Board of Education, 347 U.S. 483, 495 (1954). Short: Brown, 347 U.S. at 495. The party name stays italicized (or underlined, if your reader wants underlining).

Pick the first party's name unless that party is a governmental entity or a common litigant that would not distinguish the case. For Kimbrough v. United States, use Kimbrough. For United States v. Booker, use Booker. If the case name already appears in the accompanying text, Rule 10.9 lets you drop the name entirely and write 347 U.S. at 495—but only if there is no ambiguity about which case you mean.

"Id." (Rule 4.1) refers to the immediately preceding authority, whatever kind of source it is. Italicize it, including the period. Capitalize it when it starts a citation sentence; leave it lowercase inside a citation clause. Add "at" and a new pinpoint only if the page changes: Id. at 502.

The rule that trips students: in law review footnotes, you may use "id." only if the preceding footnote cites a single authority. If footnote 12 is a string cite of three cases, footnote 13 cannot begin with "Id."—the reader would not know which of the three you mean. Use a case short form or supra instead. Within a single footnote, "id." can follow the authority cited immediately before it in that same footnote.

Two more constraints. "Id." never refers to an internal cross-reference (do not write "Id." to mean "see the footnote above"; use supra note 12). And do not use "at" before a section or paragraph symbol: it is Id. § 1983, not Id. at § 1983. The Bluebook does not use "ibid." or "op. cit." at all.

"Supra" (Rule 4.2) points back to an earlier full citation by footnote number: Sunstein, supra note 12, at 45. It is available for books, journal articles, legislative hearings, court filings, unpublished materials, and most other secondary and miscellaneous sources.

It is generally forbidden for cases, statutes, constitutions, legislative materials other than hearings, restatements, model codes, and regulations. Those sources have their own short forms, so writing "Brown, supra note 3" in a law review footnote is a rules error, not a style choice. (Court documents are looser; some briefs use supra for cases, but do not do it in a graded Bluebook exercise or on a journal write-on.)

Use "hereinafter" when a source's name is long or when one author has several cited works, so that "supra note 12" would be ambiguous. Assign it in brackets at the end of the full cite: [hereinafter Restatement Comment]. Then cite the tag plus supra thereafter.

Statutes (Rule 12.10): after a full cite to 42 U.S.C. § 1983, the short forms are 42 U.S.C. § 1983 (repeated without the date parenthetical), § 1983 standing alone if there is no risk of confusion with another code, or Id. Never add "at" before the section symbol.

Constitutions (Rule 11): there is no short form other than "id." Repeat U.S. Const. amend. XIV, § 1 in full every time you cannot use id.

Books (Rule 15.10) and periodicals (Rule 16.9) use the supra form: author's last name, supra note X, at page. Regulations get an abbreviated C.F.R. cite or id. Cases in court filings and record cites follow the Bluepages court-documents rule; record citations typically appear as (R. at 12.), but many courts specify a different format by local rule.

Yes, and the variation is predictable. Law journals apply Rule 10.9's footnote-window rule strictly because their editors are checking mechanically; each journal also keeps a house style sheet that may override the Bluebook on things like when to re-cite in full after a section break.

Courts vary more. Many federal and state courts have local rules or chambers preferences that limit or forbid "supra," require full citations in every section of a brief, or mandate a jurisdiction-specific citation manual entirely—California, Texas, Michigan, and New York, among others, have their own style guides that displace the Bluebook in state practice. Some schools teach ALWD Guide instead, which reaches nearly identical short-form results but organizes the rules differently.

The practical rule: follow the Bluebook for 1L legal writing and journal work, and follow the court's local rules in practice. Check the assignment sheet before you check the Bluebook.

These are the errors graders and journal editors flag most often. Run them as a checklist before you submit.