String Citations, Parallel Citations, and Order of Authorities:

1. String Citations, Parallel Citations, and Order of Authorities: Part 7 of the Legal Methods Lecture Series By Deborah Gordon

2. String Cites - Introduction • What is a string citation? • A list of multiple authorities in a single citation sentence. • When do you use a string cite? • When you synthesize a rule from more than one source • When you refer in your analysis to information from more than one authority

3. Parallel Citations - Introduction • Parallel citations are citations to more than one source (most frequently, more than one case reporter) for the same authority. • Consult the jurisdiction’s local rules to determine whether parallel cites are required.

4. When to use string cites? • Synthesizing sources • Documenting a jurisdictional split • What about multiple cites for a single proposition?

5. Formalities of a String Cite • Punctuation: use semicolons to separate authorities in a string cite. • Short form: use the full citation the first time a source is mentioned and the short form thereafter.

6. Use of “Id.” in String Cites • You may use the short form “id.” to begin a string cite when: • You are referring to the immediately preceding cite; and • That cite refers to just one source. • Example: • The sky is blue. Smith v. Brown, 25 U.S. 18 , 22 (1901). When the sky is blue, rain is unlikely. Id. at 23; Setting Sun Ass’n v. Rain Clouds, Inc., 244 F.3d 718, 727 (2d Cir. 2009). • Never use “id.” to refer to a string cite or to any source within a string cite, even the final one.

7. How to Order Authorities Within a String Cite: • Begin with any authority that is substantially more helpful or authoritative than the others (if there is one). • If no clear governing authority exists, use the order provided in Bluebook Rule 1.4.

8. Order of Authorities: General Rules • General order: • Constitutions (and foundational documents) • Statutes • Treaties • Cases • Other materials (legislative, secondary sources, etc.) • In general, citations within each category are: • Federal, state, foreign, international • Alphabetical • Hierarchical • Reverse chronological order

9. Order of Authorities: Cases • Bluebook Rule 1.4(d) • Cite cases in the following order: • (1) federal • (2) state • (3) foreign • (4) international • Cases decided by the same court are arranged in reverse chronological order.

10. Order of Authority: Federal Cases • The most common federal cases are cited in the following order: • Supreme Court • Courts of appeals • Court of Claims, special Appeals courts (bankruptcy, patents)  • district courts • district bankruptcy courts • Court of federal claims and tax court • administrative agencies (alphabetically by agency)

11. Order of Authority: State Cases • After all federal cases are cited, state cases may be cited as follows: • Alphabetically by state • Then by rank within each state and • Then in reverse chronological order within each of the same ranked courts • Example: • See, e.g., Mitchell v. Davis, 598 So. 2d 801, 803 (Ala. 1992); Robinson v. Robinson, 914 S.W.2d 292, 295 (Ark. 1996); Bercume v. Bercume, 704 N.E.2d 177, 180 (Mass. 1999); Schuler v. Schuler, 416 N.E.2d 197, 200 (Mass. 1981); Harris v. Harris, 500 N.E.2d 1359, 1362 (Mass. App. Ct. 1986).

12. Order of Authority: Other Materials • Refer to Bluebook Rule 1.4 for how to order all other materials, including legislative materials, briefs, and secondary sources. • You may change the order of authority within a string cite by using citation signals.

13. Parallel Cites - Introduction • Parallel citations are citations to more than one source (most frequently, more than one case reporter) for the same authority. • Example: Cotter v. Pelligrino, 567 Mass. 25, 31, 449 N.E.2d 12, 18 (1992).

14. Local Rules • Some states do not publish their own reporters so parallel cites are not needed. • Some courts in states that publish their own reporters require lawyers to provide parallel citations for each cited case decided by a court in that jurisdiction. • Some courts always require parallel cites.

15. If the Local Rules Require Parallel Cites: • The two citations should be separated by a comma in your citation sentence. • Cite to the state reporter first, followed by the regional reporter. • Provide pinpoint cites for each reporter. • Example: Harris v. State, 222 Ga. App. 56, 61, 473 S.E.2d 229, 232 (Ct. App. 1996).

16. If the Local Rules Require Parallel Cites: • If the state is obvious from the official reporter title, omit the state abbreviation from the parentheses with the date. • Omit the name of the court from the parentheses if it is the highest court in the state. • If the decision is from a lower state court, keep the remaining court abbreviation in the parentheses. • Example: Harris v. State, 222 Ga. App. 56, 61, 473 S.E.2d 229, 232 (Ct. App. 1996).

17. If the Local Rules Do Not Require Parallel Cites: • Refer to Table 1 starting at page 198 in your Bluebook to determine which reporter to cite. • If only the regional reporter must be cited, provide the abbreviation of the court in the parentheses. • Example: • Parallel: Cotter v. Pelligrino, 567 Mass. 25, 31, 449 N.E.2d 12, 18 (1992). • No Parallel:  Cotter v. Pelligrino, 449 N.E.2d 12, 18 (Mass. 1992).

18. Short Forms and Use of “Id.” • Use short forms for both cites in the parallel citation. • “Id.” replaces only the official (first, state) reporter. • Examples: • Standard Short Form: Cotter, 567 Mass. at 31, 449 N.E.2d at 18. • Use of “Id.”: In Cotter, the court held that the sky is blue. Id., 449 N.E.2d at 18.