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Bluebook Citation

How to Cite a State Court Case

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How to Cite a State Court Case

Cite a state case as case name, volume, reporter abbreviation, first page, pincite, then a parenthetical with the court and year — e.g., Goodridge v. Dep't of Pub. Health, 798 N.E.2d 941, 948 (Mass. 2003). Under Rule 10.3.1 you normally cite the regional reporter alone, but many state courts require a parallel official citation, so check Bluepages Table BT.2 and the court's local rule before you file.

What are the required pieces of a state case citation?

Rule 10.1 gives you five slots: (1) the case name, (2) the volume, reporter abbreviation, and first page, (3) the pinpoint page, (4) a parenthetical identifying the court and the year of decision, and (5) any subsequent history. Only the first four appear in most citations.

Work through a real example. The full cite is Li v. Yellow Cab Co., 532 P.2d 1226, 1243 (Cal. 1975). "532" is the volume of the Pacific Reporter, Second Series; "1226" is the first page; "1243" is the page you are actually relying on; "Cal." is the deciding court; "1975" is the year. If you are quoting or citing a specific proposition, the pincite is not optional — omitting it is the single most common error in student work.

Which reporter do you cite, and do you need a parallel citation?

Rule 10.3.1 sets the default: cite the regional reporter — A.3d, N.E.3d, N.W.2d, P.3d, S.E.2d, So. 3d, or S.W.3d — and nothing else. Table T1.3 tells you, state by state, exactly which reporter to use and for which courts. That is the rule for law review footnotes, seminar papers, and any document not filed in a state court.

Two things override the default. First, Rule 10.3.1(b) and Bluepages B10.1.3 require parallel citations when the local rules of the court you are filing in demand them; Table BT.2 collects those jurisdiction-specific rules. New York and California appellate courts, among others, expect the official reporter first: Palsgraf v. Long Island R.R. Co., 248 N.Y. 339, 341, 162 N.E. 99, 99 (1928). Second, some states have stopped publishing an official reporter entirely, and T1.3 will say so.

Watch the two big West state-specific reporters. T1.3 directs you to California Reporter (Cal. Rptr. 3d) for Court of Appeal decisions and to New York Supplement (N.Y.S.3d) for New York's intermediate and trial courts, rather than to P.3d or N.E.3d. Check T1.3 for the state you are citing rather than assuming the regional reporter is right.

How do you build the court-and-date parenthetical?

Rule 10.4(b) is a redundancy rule: identify the court, but omit anything the reporter already conveys unambiguously. Because a regional reporter covers several states, you must name the state. Because the highest court of a state is the default, you drop its name — so Massachusetts's Supreme Judicial Court is just (Mass. 2003), not (Mass. Sup. Jud. Ct. 2003).

For any court other than the state's highest, add the court abbreviation from Table T7: (Cal. Ct. App. 2019), (N.J. Super. Ct. App. Div. 2018), (Tex. App. 2020), (Ohio Ct. App. 2017). If the reporter itself identifies the state — Cal. Rptr. 3d, N.Y.S.3d, A.D.3d — do not repeat the state in the parenthetical. New York trips people up: the Court of Appeals is the high court, so (N.Y. 2019); the Supreme Court is a trial court, so (N.Y. Sup. Ct. 2019).

How do you cite states that use public-domain (neutral) citations?

Rule 10.3.3 governs medium-neutral citations, which a substantial minority of states have adopted. The format is: case name, year, state or court code, sequential opinion number, paragraph pincite, then the regional reporter cite if available. The parenthetical disappears because the year and court are already in the neutral cite.

The template looks like this: Party v. Party, 2019 ND 42, ¶ 14, 926 N.W.2d 500, 505. Wisconsin uses 2019 WI 42; Maine uses 2019 ME 42; Illinois uses 2019 IL 123456 for the supreme court and 2019 IL App (1st) 180123 for the appellate court; Ohio uses the 2019-Ohio-1234 form. Utah, Montana, South Dakota, Oklahoma, New Mexico, Vermont, Colorado, and Arkansas have their own variants. Confirm the exact format in T1.3 before you use it — the state codes and the placement of the paragraph pincite vary.

How do you abbreviate the case name?

Rule 10.2.2 governs names inside citations (as opposed to Rule 10.2.1, which governs names in textual sentences). In a citation, abbreviate every word listed in Table T6 and every geographic word in Table T10, drop all parties but the first on each side, delete "et al.," and omit business designations like "Inc." when the name already contains "Co." or similar. "Department of Public Health" becomes "Dep't of Pub. Health."

Government-party names have their own trap under Rule 10.2.1(f). When a state is a party in a case decided by that state's own courts, use only "State," "Commonwealth," or "People" — whichever the deciding court uses. When you cite that same case in a document submitted to a different jurisdiction, replace it with the state's name: State v. Smith becomes Michigan v. Smith. Keep procedural phrases like "In re" and "ex rel.," but drop "on the relation of" style expansions.

What do the short forms look like?

Rule 10.9 allows a short form once you have given a full citation in the same general discussion and the reader can locate it. The standard form drops the first page and the parenthetical: Goodridge, 798 N.E.2d at 953. If the case name is unmistakable from context, you can sometimes use just the reporter: 798 N.E.2d at 953. Use Id. at 953 when the immediately preceding citation is to the same case and nothing intervenes.

With a parallel citation, the short form carries both reporters: Palsgraf, 248 N.Y. at 341, 162 N.E. at 99. With a neutral citation, cite the paragraph: Party, 2019 ND 42, ¶ 14. Under Rule 4.1, "supra" is not used for cases.

How do you cite unpublished, slip, and very recent state decisions?

For a case available only on Westlaw or Lexis, Rule 10.8.1(a) requires the docket number, the database identifier with star pagination, and a full date in the parenthetical: Party v. Party, No. 19-1234, 2020 WL 1234567, at *3 (Mich. Ct. App. Mar. 12, 2020). For slip opinions not yet in any database, give the docket number, court, and exact date under Rule 10.8.1(b). Before relying on an unpublished state decision in a brief, confirm the state's rule on citing unpublished opinions — many restrict it.

Two formatting points depend on the document type. In briefs and memos, italicize or underline the case name (Bluepages B2). In law review footnotes, the case name in a full citation appears in ordinary roman type; italics are reserved for short forms and for case names used in textual sentences (Rule 2.1(a)). Finally, add subsequent history under Rule 10.7 when it matters — aff'd, rev'd, cert. denied — appended after the parenthetical.

Key Takeaways

  • The default state case cite is name, regional reporter, pincite, and a (Court Year) parenthetical: Li v. Yellow Cab Co., 532 P.2d 1226, 1243 (Cal. 1975).
  • Table T1.3 controls which reporter to use for each state and each level of court; do not guess.
  • Include a parallel official citation only when the receiving court's local rules require it — Table BT.2 tells you which do.
  • Drop the court name in the parenthetical for a state's highest court, and never repeat information the reporter already conveys (Rule 10.4(b)).
  • In neutral-citation states, the year, court code, and opinion number replace the parenthetical, and you pincite to paragraph numbers.
  • Case names are italicized in briefs but set in roman type in full citations in law review footnotes.

Frequently Asked Questions

Do I ever need three reporters in one citation?
Occasionally, in California briefs, where practice includes the official reporter, the Pacific Reporter, and California Reporter — for example, Tarasoff v. Regents of the University of California, 17 Cal. 3d 425, 551 P.2d 334, 131 Cal. Rptr. 14 (1976). This is driven entirely by state practice, not by the Bluebook's own preference. Outside such local requirements, cite one reporter.
What if the case is too old to appear in a regional reporter?
Cite the official state reporter alone and give the full court identification in the parenthetical. Regional reporters generally begin in the 1880s, so anything earlier will exist only in the official reports or in a nominative reporter. Table T1.3 lists the official reporters and their coverage dates for each state.
Which state abbreviation goes in the parenthetical — the one from T1 or T10?
Use the jurisdiction abbreviation given in Table T1.3 for the court itself, combined with the court abbreviations in Table T7. Table T10 supplies geographic abbreviations for use inside case names and institutional authors, not for the court parenthetical. They often look identical, but T1 and T7 control the parenthetical.
How do I know whether my court requires parallel citations?
Check Bluepages Table BT.2, which compiles jurisdiction-specific citation rules and style manuals, then verify against the current local rules of the specific court. This genuinely varies: some states mandate the official reporter first, some mandate their own neutral citation format, and some have adopted a state style manual that departs from the Bluebook. The local rule always wins over the Bluebook in a filed document.
Can I pincite a paragraph instead of a page in a non-neutral-citation state?
No — use page numbers when you are citing a reporter, and paragraph numbers only when the state uses a neutral citation format that numbers paragraphs. Rule 3.2 requires page pincites for paginated sources. Mixing the two signals to a reader that you copied a citation without checking it.
Do I write 'State v. Smith' or 'Ohio v. Smith'?
It depends on where you are filing. Under Rule 10.2.1(f), use 'State v. Smith' in a document submitted to Ohio courts, because the deciding jurisdiction is understood. In a brief filed elsewhere, or in a law review article, write 'Ohio v. Smith' so the reader knows which sovereign was a party.

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