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 citation does not need an introductory signal when it directly supports the proposition. Ergo, you do not need an introductory signal when citing a direct quote.
Rule 1.2(a)
My 1L Civ Pro professor would be so proud of my use of “ergo.”
E.g.
I use this one quite often.
This means “for example,” as it does in other writing. Use this where the cite is one of many that stand for the proposition. It can be used on its own or added to other signals.
Rule 1.2(a)
Accord
I love this one.
Accord is used when the cite is a direct quote but you’re adding another source in a string-cite.
Example: The “overarching subject” of the test in Rule 702 is “the evidentiary relevance and reliability.” Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579, 595 (1993); accord Fed. R. Evid. 702.
Rule 1.2(a)
See
See is used when the cited authority supports the proposition but doesn’t directly state it. There’s some sort of inference.
Rule 1.2(a)
See also
See also is used as a follow-up to see.
Example: The expert testimony is admissible because it helps the factfinder. See Fed. R. Evid. 702; see also Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579, 591 (1993).
Pro Tip: Don’t use see also unless you already have see.
Rule 1.2(a)
Cf.
Cf. is used when the cited authority is comparable to the proposition but needs some explanation.
I find that this one is useful when citing an analogous case.
Example: The Complaint should be dismissed. Cf. Case v. Cite, 123 So. 3d 456 (Court 2022) (dismissing the plaintiff’s claims in similar circumstances).
Rule 1.2(a)
But see
But see is used to show a contradiction.
Example: The sky is blue. But see Case v. Cite, 123 So. 3d 456 (Court 2022) (stating that the sky is gray).
Pro Tip: While it is not in the Bluebook, it is advisable to use a parenthetical with this one.
Rule 1.2(c)
Contra
Contra is used to cite a source that states the proposition directly contrary to yours. Note that Bluebook says you use this where no signal would be used for support.
Example: The light was red. Case A v. Cite A, 123 So. 3d 456 (Court 2022). Contra Case X v. Cite Y, 123 So. 3d 456 (Court 2022) (stating the light was green).
Rule 1.2(c)
See generally
See generally is used when you’re referencing the entire source. Bluebook recommends using a parenthetical for this one.
Example: There is a uniform method for citations that everyone should love. See generally The Bluebook (21st ed. 2020) (setting forth the rules for a uniform method of citation).
I use this one a lot for law review articles.
(Yes, I know that’s not the correct cite to The Bluebook.)
Rule 1.2(d)
Question:
What is your favorite introductory signal?
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