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 – Introductory Signals
Rule 1.2(a)
Revisiting “see also”
Rule 1.2(a)
In the last post, I included a Pro Tip to not use “see also” unless you have already used see. That is how I have always understood and used see also.
Thanks to our LinkedIn brain trust, I have learned that may not be correct.
TL;DR
You can use “see also” without “see.”
I retract the Pro Tip stating otherwise in Tip #11.
The explanation of see also in Rule 1.2 suggests that anything cited with this signal is more attenuated than see.
The explanation for see states:
“Cited authority clearly supports the proposition.”
Rule 1.2(a) (emphasis added).
The explanation for see also states:
“Cited authority constitutes additional source material that supports the proposition.”
Rule 1.2(a)
Comparing the two suggests see also is more attenuated, which has always been my understanding.
However, the explanation for see also also suggests it can be used another way:
“See also is commonly used to cite an authority supporting a proposition when authorities that state or directly support the proposition already have been cited or discussed.”
Rule 1.2(a) (emphasis added).
This suggests see also can be used as a follow-up to no signal.
Update
See also can follow both no signal and see.
Examples in Rule 4 use see also both ways.
#14 uses see and see also, so that use is not wrong.
#7 uses see also after no signal. Used this way, it seems to mean,
“This cite also supports the proposition.”
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