What is a parallel citation?
A parallel citation lists the same case in two or more reporters. State appellate decisions are often published both in an official state reporter and in one of West's regional reporters, and in a few states in a third reporter as well. Palsgraf v. Long Island R.R. Co., 248 N.Y. 339, 162 N.E. 99 (1928), is a parallel citation: the identical opinion appears at volume 248, page 339 of the New York Reports and at volume 162, page 99 of the North Eastern Reporter.
Bluebook Rule 10.3.1 governs which reporters to cite and in what order. Table T1 identifies the official reporter for each jurisdiction and tells you when an official reporter has been discontinued. That last point matters practically: many states stopped publishing official reports decades ago, so for recent decisions from those states there is no parallel cite to give, and the regional reporter is the only citation.
Federal cases almost never take parallel citations. F.3d, F. Supp. 3d, and their predecessors are the only reporters for lower federal courts. For the Supreme Court, Rule 10.3.1 and T1 direct you to cite United States Reports alone; you use S. Ct. or L. Ed. 2d only when the U.S. pagination is not yet available.
What is a pinpoint citation?
A pinpoint citation (also called a pincite or jump cite) is the page number, or range of pages, on which the specific material appears. It follows the first page of the case, separated by a comma: Roe v. Wade, 410 U.S. 113, 153 (1973). Rule 3.2(a) and Bluepages B10.1.2 require it whenever you quote, paraphrase, or refer to a particular passage.
Several formatting conventions come with it. When the material appears on the first page of the opinion, repeat the page number: 410 U.S. 113, 113. For a span, drop repetitious digits but keep at least the last two: 483, 494–95, not 494–5 or 494–495. To cite a footnote, use 'n.' with no space before the number: 347 U.S. 483, 494 n.11 (1954). Multiple non-consecutive pages are separated by commas: 113, 129, 153.
A citation without a pincite signals that you are citing the case as a whole. That is appropriate for a general reference to a decision's existence or overall holding, but it is a mistake — and in a brief, a credibility problem — for any quotation or specific proposition.
How do the two work together in a single citation?
They are not alternatives. If you give a parallel citation and you are pinciting, you must supply a pincite for each reporter, because the page breaks differ between books. The structure is: volume, reporter, first page, pincite — repeated for each reporter — followed by the court-and-date parenthetical.
Using a hypothetical to show the template: Doe v. Roe, 100 Ill. 2d 200, 205, 450 N.E.2d 500, 503 (1983). The reader who has the official reports turns to page 205; the reader who has the North Eastern Reporter turns to page 503. Supplying only one pincite in a parallel citation is one of the most common errors student writers make.
Where do you find the second pincite? Westlaw and Lexis both display star pagination for every reporter in which the case appears, so you can read the parallel page break directly off the screen without pulling the book.
When are parallel citations required, and when are they forbidden?
This varies by forum, and the variation is driven entirely by your audience. For law review footnotes and academic writing, Rule 10.3.1(b) tells you to cite only the regional reporter for state cases; adding the official reporter is treated as clutter. For documents filed in court, the Bluepages tell you to follow the rules of the court in which you are filing, and Bluepages Table BT.2 collects jurisdiction-specific citation rules and style guides.
A meaningful number of state courts require briefs to cite the official state reports, sometimes with the regional reporter in parallel; others have adopted a public domain format and require that instead; others accept the regional reporter alone. Because these rules change, verify against the current local rule or the court's style manual rather than relying on a professor's example from an older edition. For a legal writing assignment, ask which jurisdiction's convention the professor expects — many require Bluebook default rules regardless of the fictional forum.
Never add parallel citations where they are affirmatively wrong: do not append S. Ct. and L. Ed. 2d cites to a U.S. Reports citation, and do not pair a U.S.C. citation with U.S.C.A. or U.S.C.S.
How do you pincite when the source has no page numbers?
Public domain (medium-neutral) citation formats, covered by Rule 10.3.3, use the year, a court identifier, a sequential opinion number, and paragraph numbers as pincites. The form looks like: Doe v. Roe, 2004 SD 25, ¶ 14, 690 N.W.2d 100. Here the paragraph number is the pinpoint and the regional reporter citation is appended in parallel — with its own page pincite if you are pinciting the regional reporter as well.
For decisions available only in an electronic database, Rule 10.8.1(a) supplies the form, with star pagination as the pincite: Doe v. Roe, No. 21-cv-1234, 2022 WL 987654, at *3 (N.D. Ill. Mar. 4, 2022). Note the 'at' before the asterisk. Do not cite the database once the case appears in a reporter, and do not confuse a Westlaw star page with the printed page of a different reporter.
What happens to both in short-form citations?
Short forms under Rule 10.9 are essentially pincite delivery vehicles: 410 U.S. at 153. The 'at' appears in the short form even though it does not appear in the full citation. For footnotes: 410 U.S. at 153 n.7.
When the jurisdiction requires parallel citations, the short form carries both reporters, each with its own pincite: 100 Ill. 2d at 205, 450 N.E.2d at 503. 'Id.' can be used when the immediately preceding citation is to that single authority; the conventional form repeats the second reporter, as in: Id. at 206, 450 N.E.2d at 504. Rule 4.1 warns against using 'id.' when the preceding citation contains more than one authority, so check whether your preceding footnote strings several cases together.
'Id. at 155' with no reporter name is correct only when the immediately preceding citation was to a single reporter. If you switch between parallel and non-parallel conventions midway through a document, the short forms will stop making sense to the reader.
Which errors actually cost you points?
Graders and judges notice a small, predictable set of mistakes. Fix these before anything else.
- Quoting language and giving only the first page of the opinion — the single most frequent citation error in student briefs.
- Giving a parallel citation with a pincite for one reporter but not the other.
- Adding parallel citations in a law review footnote, where Rule 10.3.1(b) calls for the regional reporter alone.
- Attaching S. Ct. or L. Ed. 2d citations to a case already reported in U.S. Reports.
- Botching page spans: write 494–95, not 494–5 or 494–495; write 1101–02, not 1101–2.
- Inserting 'at' before the pincite in a full case citation — 'at' belongs in short forms, star pagination, and supra cites, not in 410 U.S. 113, 153.
- Citing a Westlaw star page as though it were a printed reporter page.