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Basics of Legal Research: Deciphering Legal Citations

Introduction to the basics and fundamentals of legal research, including information on understanding citations, and the difference between primary and secondary sources.

Reading a Legal Citation

Legal citations are references to a specific legal authority.  Like non-legal citations, legal citations are a shorthand method of identifying a source, such as a constitution, statute, reported case, regulation, treatise, or law review article.  Legal citations often include volume numbers, titles of publications, page or section numbers, and dates.  Titles of legal authorities are often abbreviated, which can make them confusing to non-law librarians who are used to working with other citation manuals.

Guidance on the proper citation format to use can be found in The Bluebook: A Uniform System of Citation, now in the Twentieth Edition.  The Bluebook is divided into the Bluepages, the Whitepages, and Tables.  The Bluepages present brief how-to instructions on basic legal citation, while the Whitepages cover citation styles and standards in more depth.  The Tables provide important instructions on how to correctly abbreviate in legal citations, including how to abbreviate the titles of state and federal primary sources.

State

State constitution citations include the abbreviated name of the constitution, followed by the amendment or article and section being cited to.  For instructions on how to cite a state constitution generally, see Rule 11 in The Bluebook: A Uniform System of Citation.

The title of the constitution is simply the name of the state, as abbreviated in Table T1.3 in The Bluebook, followed by "Const."  Abbreviate the subdivisions of constitutions, such as amendment, article, and clause according to Table T16. Use Roman numerals for articles and parts, and Arabic numerals for sections. 

Citations to Louisiana's constitution follow this format:

Title

Subdivision

La. Const.

art. I, § 3.

La. Const.

art. VI, pt. II.

State statute citations are generally composed of three parts: the title of the code, a section number, and a date.  For instructions on how to cite a state statute generally, see Rule 12 of The Bluebook: A Uniform System of Citation.

The correct form for citation to state code varies, depending on the state.  Table T1.3 in The Bluebook explains how to abbreviate the name of each state code correctly and indicates how to correctly cite the title, chapter, and/or volume of each state code.  Table T1.3 is organized alphabetically by the name of the state, and the information on how to cite the state code is found under the "Statutory compilations" section.

The trickiest part of a Louisiana state statute citation to decipher is the date.  Louisiana state statutes citations can direct the reader to the main volume, the supplement to that volume, or the main volume and the supplement of that volume.  The date will tell the reader where the statutory language is found.  

The current Louisiana Code is referred to as the 1950 code, because that is the last time the entire code was revised. If the language of the statute is in the main volume only, for citation purposes you will use the revision date on the spine of that volume. If you are using the Louisiana legislature's compilation of laws online, you can use the year of the legislative session the law is listed as current through.  

           

 

Other states sometimes have their own rules governing citation beyond The Bluebook, so when practicing in a particular state, it is important to be aware of any local rules or practices regarding citation.  In some cases, states may indicate that a citation form other than what is required in The Bluebook can be used.  For example, according to The Bluebook, Georgia's Official Code of Georgia Annotated should be abbreviated as Ga. Code Ann.  According to § 1-1-8 of the Official Code of Georgia Annotated, however, the Georgia code "may be cited or referred to as 'O.C.G.A.'"  As such, when practicing in Georgia, it would be correct to cite to O.C.G.A. rather than Ga. Code Ann.

State case law citations are generally made up of three parts: the name of the case, the published source in which the case may be found (called "reporters"), and a parenthetical indicating the court and year of decision.  Citations may also include other parenthetical information and the subsequent history of the case, if necessary.  For instructions on how to cite a state case generally, see Rule 10 of The Bluebook: A Uniform System of Citation.

You may come across different types of citations when you are looking for cases because the official rules governing citation of Louisiana cases in Louisiana courts changed. Though the reporter citation is no longer the official citation format according to Louisiana Supreme Court Rules, Part G, Section 8, which now requires a public domain format, it is still the required parallel citation.

Citations found in West's print reporters will begin with the volume of the reporter, the name of the reporter series, and the first page of the opinion. For example, the Southern reporter citation for Oubre v. La. Citizens Fair Plan is 79 So.3d 987. That is, the case is located in the 79th volume of the Southern reporter, third series on page 987. Remember that the reporter series starts over after the 999th volume. There are currently three series of Southern reporters-- So. (Southern reporter), So.2d (Southern reporter, second series), and So.3d (Southern reporter, third series).

This citation includes both the required public domain citation (docket number, court and date of decision) and the parallel West citation:

You may also see other citation formats, especially for older cases. Older Louisiana cases from the 1800s may have other citations in other formats because there were several different reporters in the early days of statehood, but the format convention is the same.

The case names you come across in citations will often be abbreviated.  For help interpreting the abbreviations, see Table T6 and T10 in The Bluebook, which cover case name and geographical abbreviations. Table T1 in The Bluebook has the reporter names' abbreviations, first for federal and then for state reporters. Often, a case will have more than one reporter listed because they are published in more than one place.  This is called parallel citation; you will find the case in both reporters.

Federal

Federal constitution citations include the title of the constitution, followed by the amendment or article and section being cited to. For instructions on how to cite a federal constitution generally, see Rule 11 of The Bluebook: A Uniform System of Citation.

The title of the constitution is U.S. followed by "Const."  Abbreviate the subdivisions of the constitution, such as amendment, article, and clause according to Table T16. Use Roman numerals for articles and parts, and Arabic numerals for sections and clauses. 

Citation to the U.S. Code look like this:

Title

Subdivision

U.S. Const.

art. I, § 8, cl. 1.

U.S. Const.

amend. XIV, § 1.

U.S. Const.

pmbl.

Federal statute citations are composed of four parts: the title number, the abbreviated name of the code, a section number, and the year of the cited code edition (not the year the law was passed).  For instructions on how to cite a federal statute generally, see Rule 12 of The Bluebook: A Uniform System of Citation.

Citations can be to unofficial, annotated versions of the United States Code, the United States Code Annotated and the United States Code Service if they include a reference to the publisher.

Title Number 

Name of the Code 

Section Number 

Publisher & Date

35

U.S.C.

§ 271

(2012)

35

U.S.C.A.

§ 271

(West 2012)

35

U.S.C.S.

§ 271

(LexisNexis 2012)


Citations may direct the researcher to the main volume, the supplement or both.  The United States Code is only codified once every six years.  Each year in between, they release a supplement, numbered Supplement I, Supplement II, etc.  As such, when citing to the supplement of the United States Code, cite "Supp." followed by the Roman numeral assigned to that supplement.

Statutory language is found in the main volume of the Code only.


1 U.S.C. § 7 (2006).

Statutory language is found in a supplement to the Code only.


15 U.S.C. § 2069 (Supp. II 2008).

Statutory language is found in both the main volume of the Code and a supplement to the Code.


29 U.S.C. § 623 (2006 & Supp. II 2008). 

United States Supreme Court case citations frequently have parallel citations (multiple citations).  United States Reports (U.S.) is the official reporter, but there are often citations to the Supreme Court Reporter (S. Ct.) and U.S. Supreme Court Reports, Lawyer's Edition (L. Ed.). For instructions on how to cite a federal case generally, see Rule 10 of The Bluebook: A Uniform System of Citation.

You do not need to indicate the court in the date parenthetical for the United States Supreme Court.  For Courts of Appeals decisions, you will see an abbreviation to the circuit court in which the case was decided before the date (for example, 1st Cir., 2d Cir., 3d Cir.).  For federal district courts, you will see the abbreviation for district (D.) or a regional district (for example, E.D. for Eastern District, M.D. for Middle District) followed by the abbreviation for the state.  Table T7 in The Bluebook: A Uniform System of Citation has a list of abbreviations for court names.

Some examples:

Miranda v. Arizona, 384 U.S. 436, 86 S.Ct. 1602 (1979)

Watson v. Shell Oil Co., 979 F.2d 1014 (5th Cir. 1992)

In Re: Katrina Canal Breaches Consol. Litig., 601 F.Supp.2d 809  (E.D.La. 2009)