Integrating Citations into
Memos
. . . How many
authorities to cite; when
and how to cite;
plagiarism; signals; etc.
Why Use Citations?
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Lead reader to your sources.
Show depth and breath of research.
Give attribution.
When to Use Citations
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In the discussion section
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Typically not in the issue, brief
answer, facts, or conclusion
Using Citations
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When you assert a legal principle
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A contract must be supported with adequate
consideration. CITE.
When you refer to or describe the content
of a legal authority
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The court ruled that . . . . CITE.
Using Citations
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When you quote from a source
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A lawyer must use the degree of skills
commonly exercised by a “reasonable, careful
and prudent lawyer.” CITE.
When you borrow an idea, even when you
do not use the language verbatim
Placement Options (ALWD 43)
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Citation sentence.
Citation clause.
Embedded citation.
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Appendix 6.
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Citation Placement: Rule 43
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Citation sentence
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Cited authority supports
the entire preceding
sentence.
Comes at the end of the
sentence (stands alone).
Starts with a capital
letter, ends with a
period.
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Citation clause
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Cited authority supports
only part of the
sentence.
Falls within the
sentence.
Begins (and usually
ends) with a comma.
Citation Sentence
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Reasonable doubt is that doubt which
would cause the court to waver on its
certainty of the defendant’s guilt. Avila
v. State, 745 So. 2d 983, 985 (Fla. 4th
Dist. App. 4th 1999).
Citation Clause
The Court has observed that employers
and unions must have significant
freedom in creating seniority systems,
Cal. Brewers Assn. v. Bryant, 444 U.S.
598, 608 (1980), but this freedom is not
unlimited, Nashville Gas Co. v. Satty, 434
U.S. 135, 140 (1977).
Another Citation Clause

False imprisonment is a general intent
crime, State v. Graham, 468 So. 2d
270, 271 (Fla. 2d Dist. App. 1985);
therefore, if Murphy is found to have
falsely imprisoned Trainor, the intent
element will be satisfied.
Embedded Citations
In Meritor Savings Bank v. Vinson,
477 U.S. 57, 66 (1986), the Court
indicated that a plaintiff can establish
a claim by showing that the
harassment created a “hostile or
abusive work environment.”
Full Citations (Cases)
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The first time you cite a case, you must
include the full citation. The components
of a full citation are:
Components of Full Citation
(ALWD 12)
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Both parties’ names (EITHER underline or
italicize the case name);
The volume number of the reporter;
The reporter abbreviation;
An initial page number;
A court abbreviation (unless the court can be
ascertained from the reporter);
The date on which the case was decided.
Examples
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Crandall v. Grandoff, 734 P.2d 1257 (Mont.
1992).
Foster Bros. v. Indep. Truckers Co., 888 F.
Supp. 23 (S.D. Fla. 1984).
Pinpoint Citations (ALWD 5.2)
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Include a pinpoint cite whenever
possible so that the reader can locate
the exact page on which the relevant
information is found.
The pinpoint citation follows the initial
page number and is separated from the
initial page number by a comma and
one space.
If the pinpoint cite is identical to the
initial page number, STILL REPEAT that
page number.
Examples
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Crandall v. Grandoff, 734 P.2d 1257,
1259 (Mont. 1992).
Foster Bros. v. Indep. Truckers Co.,
888 F. Supp. 23, 23 (S.D. Fla. 1984).
Jackson v. Tyler, 45 F.3d 134, 134136 (2d Cir. 1995).
Subsequent History (ALWD
12.8 and 12.10)
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Whenever you cite a case in
full, you must include
subsequent history.
Subsequent history tells the
reader what happened to that
case during the appellate
process (for example, affirmed,
reversed, cert. denied, etc.).
Subsequent history is “tacked
onto” the full case cite with a
comma.
Example
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A school cannot order the search of a student’s
locker without probable cause. Smith v. Indep.
Sch. Dist., 437 N.W.2d 97, 98 (Minn. App. 1st
Dist. 1984), aff’d, 440 N.W.2d 1439 (Minn.
1985).
Shepard’s/KeyCite.
Short Cites
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Use id. if possible.
May be used with cases,
statutes, etc.
ALWD 11.3 + specific
sources, like 12.21.
Refers to the immediately
preceding source.
Id.
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Indicate any particular variation in which the
subsequent citation varies from the former.
Assume different page numbers:
Jones v. Smith, 19 F.3d 14, 16 (3d Cir. 1994).
Id. at 15.
Id.
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Assume same page numbers:
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Jones, 19 F.3d at 14.
Id.
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The period in id. is underlined or italicized.
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Id.
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Id. used after a signal is NOT capitalized.
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Correct: See id. at 19.
Incorrect: See Id. at 19.
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Tip.: Convert id.’s at the end.
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Other Short Cites - Cases
(ALWD 12.21)
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If the case name (or part of the
case name) is referred to in the
text, use the short form that
includes the volume number,
reporter abbreviation, and pinpoint
page number.
Examples - Options
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In Smith, the court held that a school
could not order the search of a student’s
locker without probable cause. 437
N.W.2d at 98. (citation sentence)
In Smith, 437 N.W.2d at 98, the court
held that a school could not order the
search of a student’s locker without
probable cause. (embedded citation)
Short Citation - Cases
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If the case name (or part of the case name)
is not referred to in the text, use the short
form that includes one party’s name, the
volume number, reporter abbreviation, and
pinpoint page number.
Example
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A school cannot order the search of a
student’s locker without probable cause.
Smith, 437 N.W.2d at 98.
Citing Statutes - Citation
Sentences
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The first time you cite a statute, include a
full citation.
 You must consult Appendix 1 to
determine the information needed for
your jurisdiction.
After that, you can use a short cite -- either
id. or forms in ALWD 13.4.
Statutes - Embedded Citations
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If you refer to a statute in the text,
do not abbreviate the code; instead,
spell it out.
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Correct: Georgia Code Annotated § 837
provides that . . . .
Incorrect: Ga. Code Ann. § 837
provides that . . . .
Statutes - Subsections
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There is not a space between the main
section and the subsection.
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Correct: 838.015(1).
Incorrect: 838.015 (1).
Separate subsections with a comma or
hyphen (span)
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Correct: 383.015(1), (3)
Correct (span): 383.015(1)-(3)
Signals (ALWD 44)
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Link between the text and the
citation.
Tells the reader the type and degree
of support that the citation gives the
textual sentence.
Do Not Use a Signal If:
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The cited authority directly
supports the stated proposition.
The cited authority identifies the
source of a quotation.
The cited authority merely
identifies the authority referred to
in the text.
Signals
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See: Use when the cited authority (a) supports the
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Accord: Use to show that two or more
stated proposition implicitly or (b) contains dicta
that supports the proposition.
authorities state or support the proposition
but the text quotes or refers to only one; the
others are then preceded by “accord.” Also use to
show that the law of one jurisdiction is in accord
with that of another jurisdiction.
Signals -- continued
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See also: Use to cite additional material that supports the
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Cf.: Use when the cited authority supports the stated
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Negative signals: Contra; but see; but cf.
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See generally: Use when the cited authority is presented as
proposition. Support under this signal is not as strong or
direct as when no signal or “see” is used. “See also” may be
used when the cited authority supports the point made, but is
in some respect distinguishable from previously cited cases.
proposition only by analogy.
helpful background information related to the stated
proposition.
Number of Sources to Cite
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ALWD 43.3 and 43.4.
“Interested, but busy”
reader.
Avoid “string citations.”
Prefer quality and depth
over quantity.
Quotations
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Omissions = ellipsis (^.^.^.^)
Alterations = brackets
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The becomes [t]he
states becomes state[d] or state[]
Block indents
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The cite is not part of the block indent
Questions?