Citation signal

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{work, book, publish}
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Introductory signals are used in legal citations to present authorities and show how the authorities relate to propositions in textual statements. A legal writer uses an introductory signal to tell readers how her citation to legal authority supports, or does not support, her written proposition. Introductory signals organize the writer's citations into a hierarchy of strength and importance so that the reader can quickly determine the relative weight of the citation. For example, the introductory signal "See" tells the reader that the cited authority either (a) supports the stated proposition implicitly, or (b) contains dicta that support the proposition. "But see," on the other hand, tells the reader that the cited authority either (a) contradicts the stated proposition implicitly, or (b) contains dicta that contradict the stated proposition.

Introductory signals have different meanings in different U.S. citation style systems. The three most prominent citation manuals are The Bluebook: A Uniform System of Citation [1] and the ALWD Citation Manual [2] and The Maroonbook [3]. Some state-specific style manuals also provide guidance on legal citation. The Bluebook citation system is both the most comprehensive and most widely used system by courts, law firms, and law reviews. Here are examples, with explanations, of the introductory signals used in legal writing under the Bluebook system:

Signals that indicate support

  • no signal
  • E.g.
  • Accord
  • See
  • See also

Source: State v. Anderson, 141 Wash.2d 357, 5 P.3d 1247, 1253 (2000).

Signals that indicate background material

  • See generally

Signals that indicate contradiction

  • Contra
  • But See
  • But cf.

Signals that indicate a useful comparison

  • Compare _____ with _________

Signal formatting

  • Signals as the verbs of textual sentences

"Cf." becomes "compare" and "e.g." becomes "for example" when used in this way.

  • Capitalizing Signals

Signal Placement and Typeface

One space should separate an introductory signal from the rest of the citation, with no punctuation in between.

Example: See American Trucking Associations v. United States EPA, 195 F.3d 4 (D.C. Cir. 1999).

Do not italicize a signal if it is being used as a verb.

Example: For a discussion of the Environmental Protection Agency's failure to interpret a statute to provide intelligible principles, see American Trucking Associations v. United States EPA, 195 F.3d 4 (D.C. Cir. 1999).

Order of signals

(See The Bluebook: A Uniform System of Citation [4]) When one or more signals are used, the signals should appear in the following order:

     1.[no signal]
     2. E.g.,
     3. Accord
     4. See
     5. See also
     6. Cf.
B. Signals that indicate a useful comparison
     7. Compare...[and]...with...and...
C. Signals that indicate contradiction
     8. Contra
     9. But see
     10. But cf.
D. Signal that indicates background material
     11. See generally

When multiple signals are used, the signals must be consistent with the proper order of authorities. Also, signals of the same basic type - supportive, comparative, contradictory, or background - are strung together within a single citation sentence and separated by semicolons. Signals of different types should be grouped in different citation sentences. For example:

"See Mass. Bd. of Ret. v. Murgia, 427 U.S. 307 (1976) (per curiam); cf. Palmer v. Ticcione, 433 F.Supp. 653 (E.D.N.Y 1977) (upholding a mandatory retirement age for kindergarten teachers). But see Gault v. Garrison, 569 F.2d 993 (7th Cir. 1977) (holding that a classification of public school teachers based on age violated equal protection absent a showing of justifiable and rational state purpose). See generally Comment, O’Neill v. Baine: Application of Middle-Level Scrutiny to Old-Age Classifications, 127 U. Pa. L. Rev. 798 (1979) (advocating a new constitutional approach to old-age classifications)."

When "e.g." is combined with another signal, the placement of the combined signal is determined by the non-e.g. signal. For example, the combined signal "see, e.g." should be placed where the "see" signal would normally fall.

However, within a citation clause citation strings can contain different types of signals. These signals are separated by semicolons.

[edit] Order of authorities within each signal

(See The Bluebook: A Uniform System of Citation [5])

Authorities within each signal are separated by semicolons.

If one authority is considerably more helpful or authoritative than the others cited within a signal, it should precede others. Except in this situation, cite authorities in the order in which they are listed below:

(a) Constitutions and other foundational documents. Cite in the following order: 1. federal 2. state (alphabetically by state) 3. foreign (alphabetically by jurisdiction) 4. foundational documents of the United Nations, the League of Nations, and the European Union (in that order). Constitutions of the same jurisdiction are cited in reverse chronological order.

(b) Statutes. Cite statutes in the following order, according to the jurisdictional hierarchy below: federal, state, foreign, and international.

1. Federal: (i) statutes in U.S.C., U.S.C.A., or U.S.C.S.; (ii) other statutes currently in force, by reverse chronological order of enactment; (iii) rules of evidence and procedure; (iv) repealed statutes, by reverse chronological order of enactment.

2. State (alphabetically by state): (i) statutes in the current codification (by order in the codification); (ii) statutes currently in force but not in the current codification (by order in the codification); (iii) rules of evidence and procedure; (iv) repealed statutes (by reverse chronological order of enactment).

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