http//www.ualr.edu/cmbarger/shortfrm.htm Short Form Citations Updated February 24, 2006 General rule Once you have cited an authority in full, you should use a short form citation to it the next time that authority is used in the same section of your brief or memorandum (i.e., in the rule explanation of one particular issue). INCLUDEPICTURE http//www.ualr.edu/cmbarger/_themes/strtedge/astrbul1e.gif MERGEFORMATINET HYPERLINK http//www.ualr.edu/cmbarger/shortfrm.htm l idid Using id. INCLUDEPICTURE http//www.ualr.edu/cmbarger/_themes/strtedge/astrbul1e.gif MERGEFORMATINET HYPERLINK http//www.ualr.edu/cmbarger/shortfrm.htm l non-consecnon-consec Non-consecutive authorities INCLUDEPICTURE http//www.ualr.edu/cmbarger/_themes/strtedge/astrbul1e.gif MERGEFORMATINET HYPERLINK http//www.ualr.edu/cmbarger/shortfrm.htm l parallelparallel Parallel citations INCLUDEPICTURE http//www.ualr.edu/cmbarger/_themes/strtedge/astrbul1e.gif MERGEFORMATINET HYPERLINK http//www.ualr.edu/cmbarger/shortfrm.htm l suprasupra Using supra INCLUDEPICTURE http//www.ualr.edu/cmbarger/_themes/strtedge/strrulee.gif MERGEFORMATINET Using id. (and deciding when not to use id.) First, a quick review of the short form id. The short form id. (you can either underline it or use italics) is an abbreviation for the Latin word idem, meaning the same. Since its an abbreviation, it must always have a period. (Note if youre underlining, underline the period, too) Id. is the short form to use when the citation refers to the same thing you cited in the very last citation–as long as that citation referred to only one source. Youre telling the reader to look at that source again, whether its a case, a statute, a book, or an article the kind of authority doesnt matter. You can use id. to refer to any of them. Capitalize id. when it begins a citation sentence. Do not capitalize id. when you use it in a citation clause. When the citation to your source hasnt changed in any way, you need not say anything more than id. When the source is one that uses page numbers, and the page number is different from the page you just cited, no problem You can still use id., but add the preposition at (not underlined or italicized) and the new page number (also neither underlined nor italicized remember, id. is the only foreign word here). When the source uses a different sort of sub-unit, like a section or paragraph, indicate a different section or paragraph by citing the new sub-unit after id. Here are some examples Full citation McDonald v. Eubanks, 731 S.W.2d 769, 770 (Ark. 1987). Short form still citing page 770 Id. Short form now citing page 771 Id. at 771. Remember, you can use id. for any kind of authority. Heres an example of id. with a statute Full citation Ark. Code Ann. 9-12-312(a) (1991). Short form for same section Id. Short form for different section Id. 9-12-312(c). You cannot use id. if the preceding citation refers to more than one source. Typically, a multi-source citations is a string citation (two or more citations, connected by a semi-colon). In this situation, follow the short form rules for HYPERLINK http//www.ualr.edu/cmbarger/shortfrm.htm l non-consecnon-consec non-consecutive authorities, set out below. If you need more specific help with id. (for example, when youre working with an authority other than cases or statutes), check the ALWD Citation Manual or the Bluebook. At the end of the manuals section describing citation rules for each type of authority, youll find reference to creating short forms for that kind of authority. HYPERLINK http//www.ualr.edu/cmbarger/shortfrm.htm l toptop return to top INCLUDEPICTURE http//www.ualr.edu/cmbarger/_themes/strtedge/strrulee.gif MERGEFORMATINET Non-consecutive authorities What do you do when you cant use id. Youll have to provide the reader with a bit more information, but still not nearly as much as the full citation provided. The idea is to give the reader enough information to easily retrieve the cited source from the stack of books on the desk or from the electronic database. That generally means, therefore, that youve got to provide information concerning the type of source and specific volume, in addition to the page number. For cases, here are the basics INCLUDEPICTURE http//www.ualr.edu/cmbarger/_themes/strtedge/astrbul1e.gif MERGEFORMATINET a party name (usually the first given, but its your choice many writers use the appellee if the name is more distinctive) INCLUDEPICTURE http//www.ualr.edu/cmbarger/_themes/strtedge/astrbul1e.gif MERGEFORMATINET the volume number and reporter abbreviation and INCLUDEPICTURE http//www.ualr.edu/cmbarger/_themes/strtedge/astrbul1e.gif MERGEFORMATINET the specific page number(s).Thats all. But thats enough. Ready for some examples Full citation Lewallen v. Bethune, 593 S.W.2d 64, 66 (Ark. 1980). Short form Lewallen, 593 S.W.2d at 66. Full citation Boykin v. Alabama, 395 U.S. 238, 244 (1969). Short form Boykin, 395 U.S. at 242. BUT NEVER EVER CITE THIS WAY Lewallen at 67. Boykin at 241. Whats the problem with these citations They give the reader no indication which reporter, or which volume the case appears in. HYPERLINK http//www.ualr.edu/cmbarger/shortfrm.htm l toptop return to top INCLUDEPICTURE http//www.ualr.edu/cmbarger/_themes/strtedge/strrulee.gif MERGEFORMATINET Parallel citations Legal writers generally use a parallel citation only where a local court rule or local custom demands that they do so. Because parallel citations are so long, short forms are particularly useful for authorities that you cite often. It is permissible to use id. for the first source in a parallel citation. It cannot, however, stand for both sources. Here are some examples of short forms to Arkansas cases imagine youre writing a brief to an Arkansas court Full citation Capitol City Manor, Inc. v. Culberson, 1 Ark. App. 137, 139, 613 S.W.2d 835, 836 (1981). Short form Id. at 140, 613 S.W.2d at 837. If id. is not appropriate, because you have cited intervening authorities, follow this model Full citation Arnold Fireworks Display, Inc. v. Schmidt, 307 Ark. 316, 319, 820 S.W.2d 444, 446 (1991). Short form Schmidt, 307 Ark. at 319, 820 S.W.2d at 445. INCLUDEPICTURE http//www.ualr.edu/cmbarger/_themes/strtedge/strrulee.gif MERGEFORMATINET Using supra The short form supra is easily and often misused, to the great frustration of the reader who encounters it in a citation. The term supra simply means above thus the short form simply tells the reader The full citation is somewhere up above, but Im not telling you where The reader is then forced to read backwards through the document, looking for the elusive full citation to the authority. Not much fun. According to the leading citation manuals, supra can only be used to refer to secondary authorities. This is a sensible rule. If youre citing a primary authority, its primariness makes it important enough that you should give the reader adequate information–on the spot–to easily locate the source. Secondary authorities, in contrast, never have any mandatory force, and presumably, readers can hunt for them or not, as they feel inclined. Supra is truly only appropriately used when the document you are writing has footnotes and you wish to cite a source previously cited in full. In that instance, your citation can tell the reader exactly where, up above, to find the cited source. The reader still has to back up, but at least knows where to look. For example 7Carter, supra n. 4, at 43-44. The best rule of thumb is to write so that you can avoid using supra altogether. If the source is good enough for you to cite, why not help your reader find it easily when you cite it in short form
