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.
Tip #6, Quotation Marks (Rule 5.2(f))
These can get tricky.
1. For in-text direct quotes, start and finish your quote with quotation marks.
2. If a portion of your quote is from another source and there are quotation marks in your quote, change those to single. If there’s a quote within the quote, those become double. So on and so forth.
Basically, you change each level to the other, with the outside being normal quotation marks.
Here’s the best way I can think of to illustrate:
Original: SOURCE QUOTE AND “QUOTE ‘WITHIN’ SOURCE”
Cite: “SOURCE QUOTE AND ‘QUOTE “WITHIN” SOURCE’”
A real-life example:
Original: “The Sixth Amendment requires a jury, not a judge, to find each fact necessary to impose a sentence of death.” Hurst v. Florida, 577 U.S. 92, 94 (2016).
Cite: In Hurst v. Florida, 577 U.S. 92 (2016), the U.S. Supreme Court held “that Florida’s sentencing scheme in death penalty cases is unconstitutional because ‘[t]he Sixth Amendment requires a jury, not a judge, to find each fact necessary to impose a sentence of death.’” Asay v. State, 210 So. 3d 1, 11 (Fla. 2016) (quoting Hurst, 577 U.S. at 94).
Take it one level at a time—like nesting parentheses. Also, yes, I put a space between the levels. Bluebook doesn’t. But, we learned that I’m not the only one. Leah Tedford does, too. And, Jonathan Graham showed us an even better way to space out quotations without an entire space in his post on kerning.
3. If your entire quote is also a direct quote, you don’t need to include two levels of quotation marks.
For example:
❌ The “‘jury’s mere recommendation is not enough.’” Asay v. State, 210 So. 3d 1, 11 (Fla. 2016) (quoting Hurst v. Florida, 577 U.S. 92, 94 (2016)).
✅ The “jury’s mere recommendation is not enough.” Asay v. State, 210 So. 3d 1, 11 (Fla. 2016) (quoting Hurst v. Florida, 577 U.S. 92, 94 (2016)).
