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LRAW Research Fall 2022

Citing State Cases Generally

A case citation serves as a reference to where a court opinion is published.
To find instructions on how to cite a case generally, see Rule B10 of The Bluebook: A Uniform System of Citation.  

In its simplest form, the correct citation form has three basic parts:

  1. The name of the case (italicized or underlined for legal documents);
  2. The published source or sources in which the case may be found; and
  3. A parenthetical indicating the court and year of the decision.

NOTE: Citations may also include other parenthetical information and the subsequent history of the case, if necessary.  For now, we will focus simply on the basic features of a case citation.

1. Name of the Case

Rule B10.1.1 provides the most important rules for correctly citing the name of a case. Of particular importance are the following abbreviation rules:

  • When referring to the name of a case in a textual sentence, as opposed to a citation sentence, you should abbreviate only widely known acronyms and the words: "&", "Ass'n," "Bros.," "Co.," "Corp.," "Inc.," "Ltd.," and "No."
  • In a citation sentence, abbreviate every word you would in a textual sentence plus any word listed in Table 6 in the back of The Bluebook.  Also abbreviate states, countries, and other geographical units following the instructions in Table 10.  
  • BUT, do not abbreviate United States when it is a named party.

Read Rules B10.1.1 and Rule 10.2 to see other rules that should be followed when citing case names.  NOTE: The comma separating the case name from the source information is not italicized or underlined.

2. Published Source Where the Case May Be Found

The case name is followed by information about where the case can be found, usually in various books called case reporters.  The reporter citation will usually include the volume number of the reporter in which the case is published, the abbreviated name of the reporter, and the first page of the case in that order.  To find the correct reporter abbreviation, see Table 1 in the Bluebook.  Rule B10.1.2 explains more about citing to the correct reporter.

3. Parenthetical Indicating the Court and Year of the Decision

Case citations usually indicate the deciding court and year in a parenthetical following the reporter citation.  This information helps readers determine the weight of the case in their jurisdiction.  However, when citing decisions of the United States Supreme Court or the highest court of any state, you should not include the name of the deciding court.  Table 1.3 lists the correct abbreviations for the courts of each state.

For example, the proper Bluebook citation for the U.S. Supreme Court's Brown v. Board of Education decision is:
Brown v. Bd. of Educ., 347 U.S. 483 (1954).

Parallel Citation

Volume 390 of the South Carolina Reports next to volume 701 of the South Eastern Reporter 2d.


A reference to the same case published in two or more reporters is called a parallel citationFor example, in South Carolina, Appellate Court Rule 268 (SCACR 268), requires you to cite the volume and page number where the case is published in both the official state reporter (S.C.) and the unofficial regional reporter (S.E. and S.E.2d). 
Thus, the Williams v. Smalls South Carolina Court of Appeals case is properly cited as:
 

                 Williams v. Smalls, 390 S.C. 375, 701 S.E.2d 772 (Ct. App. 2010).

 

Like South Carolina, many states, including all those whose opinions are published in the South Eastern Reporter (South Carolina, North Carolina, Georgia, Virginia, and West Virginia), have court rules requiring parallel citation if their cases commonly appear in multiple sources.

Examples of State Case Law Citations

South Carolina
         
   Dukesv.RuralMetroCorp.,356S.C.107,587S.E.2d687(2003).
           Statev.Smith,363S.C.111,609S.E.2d528(Ct.App.2005).

NOTE: The bullets in the South Carolina court citations above represent spaces. 

Georgia
           
Smith v. State, 281 Ga. 237, 637 S.E.2d 400 (2006).
           Mallory v. Am. Cas. Co., 114 Ga. App. 641, 152 S.E.2d 592 (1966).

North Carolina
           
State v. Brown, 320 N.C. 179, 358 S.E.2d 1 (1987).
           Smith v. Dacotah Cotton Mills, Inc., 31 N.C. App. 687, 230 S.E.2d 772 (1976).

Virginia
           
Offield v. Davis, 100 Va. 250, 40 S.E. 910 (1902).
           Farah v. Farah, 16 Va. App. 329, 429 S.E.2d 626 (1993).

West Virginia
           C
line v. Paramount Pac., Inc., 156 W. Va. 641, 196 S.E.2d 87 (1973).
  NOTE: West Virginia has a single appellate court.

Maryland

Figueiredo-Torres v. Nickel, 321 Md. 642, 584 A.2d 69 (1991).
Green v. State, 91 Md. App. 790, 605 A.2d 1001 (1992).

 

Bluebook Rules for Citing Cases

  • B10, page 10 (Blue practitioner pages)
  • R10, page 94 (White pages)
  • Rule 6.1 (Abbreviations and Spacing)
    Spacing examples are on page 88.
  • Table 1.3, page 242 (Abbreviations for court reporters by state)
  • Table 6, page 304 (Abbreviations for case names)

Pincites

When the idea you are citing to, or language you are quoting, appears on a specific page of a case, you should point your reader to that page by including a pinpoint citation.  Pincites are placed after the first page of the case, separated by a comma and a space. 

When you are including parallel citations, you must provide a pinpoint citation for the reference in both the official and unofficial reporters.  For example, in the citation for Williams v. Smalls, 390 S.C. 375, 378, 701 S.E.2d 772, 774 (Ct. App. 2010), the pincites are 378 and 774.

To pincite to a range of pages, you indicate the first and last page of the range separated by a single dash, with no spaces between the page numbers and the dash, for example, 83-84. If the page numbers have three or more digits, you drop any repetitive digits other than the last two digits, for example, 1195-96.  To cite to multiple pages that are not consecutive, list each page separated by a comma and one space, for example, 119, 124, 126.

Star Paging

You can construct a proper parallel citation with information available online. Online publishers provide the citations to both reporters. 

To help you construct pincites, online publishers use star paging to indicate the page numbers in both reporters. (However, if the online publisher makes an error in the star paging, the page number in the print reporter is the source to rely on.) Throughout the text of a case, the publisher inserts an asterisk and a page number at the beginning of each new page in the official reporter. The publisher inserts two asterisks and a page number at the beginning of each new page in the unofficial reporter.

When you find a portion of a case that you may want to cite, scan backward through the text of the case, scrolling up if needed, until you see the nearest previous number with one asterisk in front of it—that's the page number for the official reporter (*378 in the example below). Repeat the process; find the portion of the case you may want to cite, and scan backward, scrolling up if needed, until you find the nearest previous number with two asterisks in front of it—that's the page number for the unofficial reporter (**774 in the example below).

Example: "We find the plain meaning of the language 'all damages' contemplates not only injury to real property, but also personal property." Williams v. Smalls, 390 S.C. 375, 378, 701 S.E.2d 772, 774 (Ct. App. 2010).

 

Notice in the Westlaw image below, how you can find all the information for parallel citation with pincites. If you click the image, it will take you to the case on Westlaw; you may need to log in to Westlaw.

Screenshot of Williams v. Smalls on Westlaw, highlighting the citation at the top: 390 S.C. 375 | 701 S.E.2d 772 and highlighting the star paging "...construing a statute: *378 [If] the statute's language is plain..." and "...the legislature. **774 Hardee v. McDowell..." shortly before the quoted portion.

 

Notice in the Lexis image below, how you can find all the information for parallel citation with pincites. If you click the image, it will take you to the case on Lexis; you may need to log in to Lexis.

highlighted screenshot from Lexis+