Melanie Kalmanson is a commercial litigation attorney and former Florida Supreme Court law clerk. She is the author of the Bluebook Wednesday Tips Newsletter. Click here to subscribe to Melanie’s newsletter.
Bluebook Tip #8, Short Case Cites (Rules B10.2 & 10.9)
Structure of a Short Case Cite
Full cite: Hurst v. State, 202 So. 3d 40 (Fla. 2016).
Short cites: Hurst, 202 So. 3d at 41.
202 So. 3d at 41.
Id. at 41.
Note, underline can be used in place of italics. For what it’s worth, I strongly prefer italics.
Short Case Cites for WL Cases
Full cite: Yonan v. Walmart, Inc., No. 0:21-cv- 61443-WPB, 2022 WL 1284285, at *2 (S.D. Fla. Mar. 14, 2022).
Short cites: Yonan, 2022 WL 1284285, at *2.
2022 WL 1284285, at *2.
Id. at *2.
Tips
In a legal document (pleading, motion, brief, etc.), a short case cite is appropriate if the case has already been cited (i.e., full cite) once. Rule B10.2.
In a law review article, a short case cite is appropriate if the case has already been cited in at least one of the preceding 5 footnotes. Rule B10.9.
The standard short cite form is one party’s name. However, you can further shorten a party’s name if the reference is unambiguous.
Full Cite: Com. P’ship 8098 Ltd. P’ship v. Equity Contracting Co., Inc., 695 So. 2d 383 (Fla. 4th DCA 1997).
Short Cites: Short Cite: Com. P’ship 8098, 695 So. 2d 383.
OR
Equity Contracting Co., 695 So. 2d 383.
How to Use Id.
Id. is used where you are citing to the source cited in the immediately preceding cite.
Example: The Third District Court of Appeal reversed the final judgment. Nationstar Mortg., LLC v. Marquez, 180 So. 3d 219, 219 (Fla. 3d DCA 2015). The Court held that “the trial court should have entered judgment in favor of Nationstar and against Ms. Marquez.” Id. at 222.
“Id.” is capitalized if it’s the beginning of a citation sentence.
Do not use a comma after “id.” and before “at.”
The period after “id.” is italicized (or underlined).
Rule of 5 (Rule 10.9(a))
This one confuses a lot of people. It mostly applies to law review articles because it’s when you’re using footnotes.
This rule means that you need a new full-cite if the case has not been cited in any form in the last 5 footnotes. “Id.” counts.
You can have more than 5 “id.“s in a row.
Practice Question
Which one of these do you use?
1. In Nationstar Mortgage, LLC v. Marquez, 180 So. 3d 219 (Fla. 3d DCA 2015), the Third District Court of Appeal held that “the trial court should have entered judgment in favor of Nationstar and against Ms. Marquez.” Id. at 222.
2. In Nationstar Mortgage, LLC v. Marquez, 180 So. 3d 219, 222 (Fla. 3d DCA 2015), the Third District Court of Appeal held that “the trial court should have entered judgment in favor of Nationstar and against Ms. Marquez.”
3. In Nationstar Mortgage, LLC v. Marquez, the Third District Court of Appeal held that “the trial court should have entered judgment in favor of Nationstar and against Ms. Marquez.” 180 So. 3d 219, 222 (Fla. 3d DCA 2015).”
Answer
From what I can tell, The Bluebook does not answer this question directly. I prefer #1 because it seems the most correct in my opinion. But I’ve seen all three.
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