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
Rules 1.2 & 1.3
Question: Can introductory signals be used for any type of source?
Answer: Yes. Rule 1.2 does not include any limitation on the type of source that can follow an introductory signal. The examples in Rule 1.2 include various types of sources.
Analyzing the Signals
Question: What is the difference between See and Cf.?
The difference is how the source supports your proposition. Use See when the source supports your proposition but requires you to draw an inference from the source. Use Cf. when your proposition is analogous to the proposition in the source. Think of it as “compare.”
Rule 1.2
(Credit to Jonathan Graham for help with this one.)
Example
Proposition: This court should grant Plaintiff’s motion for summary judgment because Plaintiff is entitled to judgment as a matter of law.
See Fed. R. Civ. P. 56 (summary judgment standard).
Cf. Case v. Cite, 123 So. 3d 456 (Court 2022) (affirming the trial court’s final summary judgment in favor of Plaintiff where Plaintiff was entitled to judgment as a matter of law).
Question: What is the difference between But see and Contra?
On these two, the difference is the level of inference required. For But see, some inference is required to reach the contrary to the proposition stated. For Contra, the cited authority directly states the opposite of the proposition stated.
Rule 1.2
Example
Proposition: City A is one of the most dangerous cities in North America.
But see Author, Article A (2022) (suggesting that crime in City A is lower than ever before).
Contra Author, Article B (2022) (stating City A is one of the safest cities in the country).
Signal Categories
Rules 1.2 & 1.3
Rule 1.2 categorizes the introductory signals.
Signals stay together with other signals in their category.
To combine citations in the same category, use a semicolon.
Signals in the same category should generally appear in the same order as they appear in Rule 1.2.
Rule 1.3
Signals in different categories go in different citation sentences.
Rule 1.3
Example
See Case A v. Cite, 123 So. 3d 456 (Court 2022); see also Case B v. Cite, 789 F. Supp. 3d 123 (Court 2022). But see Case C v. Cite, 456 So. 2d 789 (Court 2021).
See and see also are in the same category, so they go in a string-cite. But see is in a different category, so it goes in a new sentence.
Rules 1.2 & 1.3
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