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Legal Citation: Which Guide Should You Use and What Is the Difference?

Appellate Practice

Legal citation: Is it a helpful part of law school curriculum, but forgotten after graduation? If not forgotten, is it an ever-changing morass of technical detail that makes legal writing a pain? More importantly, does anybody care if your citations are perfect? Maybe. Maybe not. I, however, believe that citation is a fundamental skill for lawyers, and just as you need to keep abreast of the evolving substantive law for your practice, you also need to keep pace with the changes in legal citation, particularly for the increasing number of electronic sources that are being cited. This article explains some of the available legal citation guides and helps you determine which will work best for you.

Rule 9.800
All practitioners, trial and appellate, should be aware of Fla. R. App. P. 9.800, which is Florida’s Uniform Citation System. Although it is in the appellate rules, Rule 9.800’s introductory paragraph states that “[t]his rule applies to all legal documents, including court opinions,” so all lawyers and judges should be using it.

The best thing about Rule 9.800 is that in two short pages in a rule book,1 it provides examples of how to cite the most common legal authorities, such as cases, state, and federal, published and unpublished; statutes; and the Florida Constitution. If you do not have a rules book, then I recommend you visit The Florida Bar’s link to the Florida Rules of Appellate Procedure, which is always the most current version; print the six pages for Rule 9.800;2 and keep them within hand’s reach for quick reference. For tech-savvy practitioners, bookmark or download the rules to your desktop for easy access in case of an internet outage.

Another plus about Rule 9.800 is that it is not full of a lot of technical rules. The introductory paragraph instructs that legal authorities should be spelled out in full unless they are used as a stand-alone citation,3 and the rule recognizes a small number of accepted abbreviations that should be used in citations,4 recommends the use of pinpoint cites (they are not required, but are preferred because they are very helpful to the reader),5 and directs that case names be underlined or italicized.6 Other than that, Rule 9.800 refers to The Bluebook: A Uniform System of Citation, or if the proper citation form is not there, to the Florida Style Manual.

What Rule 9.800 lacks is any help with the use of signals, which are critical elements to proper citation; parentheticals, which are extremely helpful to the reader; and short-form citations. It also provides no guidance for citing books, articles, and internet sources or for determining the proper order for citing legal authorities. Hence, the rule’s reference to The Bluebook, which covers all that and more.

One thing to watch for with Rule 9.800 are the proposed amendments in the Appellate Court Rules Committee’s 2017 triennial report.7 The proposed amendments include examples for citing cases in their electronic format published by Westlaw and LEXIS and citations to circuit and county court decisions, recommended and final agency orders, and unpublished agency decisions. For those of you who have Bluebook nightmares, the proposed amendments elevate the Florida Style Manual above The Bluebook as the go-to source for citation forms not appearing in the rule.8 If the Florida Supreme Court approves the amendments (look for an opinion in fall 2017), they will likely take effect on January 1, 2018.

The Bluebook
The Bluebook: A Uniform System of Citation, first published in 1926, was released in its 20th edition in summer 2015. New editions, each with an abundance of changes, some more minutiae and style than substance, are generally published every five years.

Most legal scholars and writing professionals agree that The Bluebook is America’s definitive style guide, like it or not. Yes, there are other citation systems, but as legal writing scholar Bryan Garner stated in a recent article, “It appears that The Bluebook is all but impossible to keep up with — and that it will never be ‘[a]band[oned].’”9

The Bluebook contains three major parts: 1) The “Bluepages,” first introduced in the 18th edition and considerably overhauled in the 20th edition,10 are a how-to guide for basic citation; 2) the “Whitepages,” spanning 174 pages, are the meat of its citation system and contain the style rules for citing a broader range of sources; and 3) the tables, which are used in conjunction with the rules. For most practitioners, the“Bluepages” are likely all you will ever really need, and at 56 pages in the 20th edition, they are not too long or cumbersome.

Each new edition of The Bluebook is heralded in with a list of the significant rule changes, so you can quickly see what’s new.11 Some law libraries also publish charts and blogs about the changes in the new Bluebook editions.12 So, as daunting as The Bluebook may be at 560 pages, there is help to locate the changes and keep up to date. Rather than buying the new 20th edition as the spiral bound book for $38.50, The Bluebook Online can be purchased for $36 for an annual subscription, with subsequent annual renewals for $17.13

What’s great about The Bluebook? The detail, for one. It has rules for citing everything, even your grandmother’s diary. Well, maybe not that (although, arguably, Bluebook rule 17.2 on unpublished materials would cover it), but certainly her blog, tweets, and emails are covered in rule 18. Moreover, there are rules for all sorts of internet sources, electronic media and services, as well as foreign and international material. In these days of electronic legal research and globalization, legal writing reflects a wider range of authorities than the days when Southern Reporter and Florida Statutes cites were all that were needed, and The Bluebook has kept pace.

Mastering introductory signals for citations is a must for persuasive citation, as is use of parentheticals and pinpoint cites.14 Simply citing a case, without giving the reader a clue as to why you are citing it, leads to time-consuming review of the authority with the possibility that the reader will miss the point or not even bother to read the entire authority. Bluebook rule 1.2 on introductory signals explains what each signal means and should be tabbed for easy access. The Bluebook’s index includes numerous entries to quickly locate the rules for explanatory parentheticals, parenthetical indications, and how to do pinpoint cites for just about any source.

Table 6, which lists all the abbreviations to be used in citations, should also be tabbed for easy access, because using abbreviations saves space.

Bluebook drawbacks exist, however. For instance, the detail. As Bryan Garner notes, the 10th edition of The Bluebook had only 124 pages, while the 20th edition has 560 pages.15 Bluebook critics also point to a lack of uniformity arising from the frequent amendments. Since The Bluebook is being revised regularly, the correctness of your citations depends upon which edition you are using. For example, the 16th edition’s changes to the signal meanings were boycotted by some.16 Still, The Bluebook is universally accepted, and you cannot go wrong if you cite legal authorities according to its system.

Florida Style Manual
The Florida Style Manual was first developed in 1985 by legislative editor, Floyd R. Self, and members of the Florida State University Law Review.17 The idea to develop the Florida Style Manual came with the realization that The Bluebook did not specifically address Florida authorities and that citation of many state authorities, particularly those generated by the Florida Legislature, would be rendered almost meaningless if the conventional Bluebook citations forms were followed.18 The Florida Style Manual is now in its 96-page seventh edition, which was published in 2010.

The Florida Style Manual was designed to aid practitioners and scholars in the use of proper citation form for Florida legal documents by providing a user-friendly guide. It supplements Rule 9.800 and The Bluebook.19 The manual applies to all types of legal writing, from legal documents to scholarly works, and it notes where there are differing citation forms for each, with examples provided side by side.20

What’s great about the Florida Style Manual? The wealth of information and citation guidance for Florida legal documents. Considering its origins, the Florida Style Manual includes sections on citing legislative materials, including legislative journals, daily legislative bill information publications, staff analyses, committee reports, recordings and transcripts of legislative proceedings, and official legislative rules, to name a few.21 It also includes information on how bills are introduced and passed, as well as instructions on how to refer to the title of the bill, proposed committee bills, committee substitutes and amendments, and appropriation bills.22 Section five includes rules on citing statutes in text, footnotes, and stand-alone citations, with discussion about the inclusion of the year, historical references, and how to quote statutes. The manual also addresses Florida session laws; constitutional materials; and executive branch materials, including the Florida Administrative Code, Florida Administrative Weekly, and various agency decisions. Official reports by judicial committees, administrative orders, court minutes, and information identifying the judges are also covered. Only two pages apply to Florida cases, but then they are covered in Rule 9.800. The Florida Style Manual also includes capitalization and abbreviation rules, together with the five abbreviation tables and explanations of what the various types of Florida documents are and how they are prepared, which are useful additions to Rule 9.800.

If your practice requires citing a lot of governmental documents, particularly legislative materials, the Florida Style Manual should be in your office, or at least bookmarked on your computer. The manual is available for free online; bound volumes are available for a mere $15, and you can purchase a mobile version via the Rulebook at the iTunes App Store.23

ALWD Guide to Legal Citation
There has been a lot of criticism of The Bluebook over the years, primarily that it constantly changes, is not user-friendly, and its rules are overly complex and difficult to apply.24 Consequently, in 2000, the Association of Legal Writing Directors, consisting of directors and former directors of legal reasoning, research, writing, analysis, and advocacy programs from law schools, developed the ALWD Citation Manual: A Professional System of Citation.25 The ALWD Guide has had considerable acceptance in the law school teaching community, so many of our younger lawyers learned citation with this system. Since the fifth edition, published in 2014, is compatible with The Bluebook, the choice between the two is really a matter of which speaks to you best, particularly since they are comparable in price.

Like The Bluebook, the ALWD Guide has chapters on abbreviations, spelling, and capitalization, numbers, page numbers, sections and paragraphs, footnotes and endnotes, graphs and appendices, and full and short citations. There are rules for citing cases; statutes, session laws, and other legislative materials; court rules; ordinances; administrative and executive materials; treaties; books; legal and other periodicals; dictionaries, restatements, and model codes; transcripts and appellate records; speeches; interviews and letters; and video and radio programs. Importantly, there are rules for citing electronic sources, including emails, e-readers, and CD-ROMS. Plus, there is guidance for incorporating citations into documents, signals, explanatory parentheticals, and order of authorities, as well as a whole chapter on quotations.

What’s great about the ALWD Guide to Legal Citation? It is a more user-friendly guide to uniform citation that is compatible with The Bluebook. The “sidebars” provide useful background information; the numerous charts; and the red triangles to designate required spacing in citations. At $52, however, it is the most costly guide, but you might find it for less on

Introduction to Basic Legal Citation
In the summer of 2016, Cornell Law School Professor Emeritus Peter Martin, aided by a team of students enrolled in a graduate software engineering course at Cornell, released the latest edition of Introduction to Basic Legal Citation, which is available online as well in three e-book formats (PDF, a version for Kindles and e-readers using the Mobi format, and ePub). This work first appeared in 1993, but since it is now an online publication, it is not tied to any publication cycle and improvements can be made periodically.27

Although Introduction to Basic Legal Citation comes from a law school, and most law schools use The Bluebook or ALWD Guide to teach citation, Basic Legal Citation is focused on the authorities most frequently cited in professional writing and aims at mastering those basics, rather than pinning down all possible citation situations.28

So what is in Introduction to Basic Legal Citation? Explanation of basic citation principles; rules on how to cite electronic sources, cases, statutes, bills and session laws, Internal Revenue Code, uniform acts, local ordinances, treaties, agency regulations and adjudications, executive orders and proclamations, court rules, books, and law journals, along with examples of how to cite those materials. Like all other citation systems, accepted abbreviations are provided, and there are rules on underlining and italics. Plus, there is a section on placing citations in context, which includes discussion of signals, order of authorities, and short citation forms. Basic Legal Citation also includes a description of the significant changes in The Bluebook and cross-reference tables to The Bluebook and ALWD Guide, as well as links to The Indigo Book.

The benefits of Introduction to Basic Legal Citation are that it is free and viewable in many different formats. It focuses on what practitioners need to know to cite the most common authorities, so it is not cluttered with a lot of rules for authorities you will never use. The examples provided for the citations, which open boxes with the topic highlighted, allow you to see exactly what the rule is speaking about.

The Indigo Book
The latest word on citation is The Indigo Book: An Open and Compatible Implementation of a Uniform System of Citation. While indigo is a shade of blue, the WPA poster cover on The Indigo Book and its cover statement that it is not affiliated with The Bluebook clearly signal it is not The Bluebook. Rather, it is a free Creative Commons-dedicated implementation of The Bluebook’s citation system that was compiled by a team of students at New York University School of Law under the direction of Professor Christopher Jon Sprigman. The original edition of The Indigo Book is compatible with the 20th edition of The Bluebook, and the last modification was on May 2, 2016. It is roughly equivalent to The Bluebook’s “Bluepages,” but it provides deeper guidance for citing bills and legislative history that the “Bluepages”lack.29

Inside The Indigo Book are background rules on in-text citations, signals, capitalization, and the order of authorities within each signal; rules on citing cases, including guidance of the weight of authority and explanatory parentheticals; and rules on citing federal and state statutes, rules of evidence and procedure, uniform acts, administrative rules and regulations, federal tax materials, and legislative materials, and it includes short-form citations for legislative and administrative materials. There are rules for citing court or litigation documents from your own case or another case and short forms for citing court documents, as well as capitalization rules within the text of court documents and legal memoranda. There are sections on citing books and nonperiodicals; journals, magazine, and newspaper articles; and internet sources. Plus, the general principles for explanatory parentheticals and quotations are included. There are also 20 tables with abbreviations for federal and state materials; legislative documents; intergovernmental organizations, like the United Nations; case names; geographic terms; month names; and publishing terms, to name just a few.

Sprinkled throughout The Indigo Book are “Indigo Inklings,” which provide some insight and some much-needed explanation for the rules of citation.

What is great about The Indigo Book is that it is absolutely free of charge and copyright restrictions, so you can print it and copy it. As Professor Sprigman wrote in the introduction, “Considering that the Uniform System of Citation has become a basic piece of infrastructure for the American system of justice, it is vital that pro se litigants, prisoners, and others seeking justice but who lack resources are given effective access to the system lawyers use to cite to the law. That interest in access and basic fairness is part of what motivated The Indigo Book’s creation.”30

In its PDF version, The Indigo Book is 201 pages, with the tables starting on page 67. Its length is similar to The Bluebook “Bluepages” and is a manageable amount of information. As for the negatives about The Indigo Book, it is perhaps too soon to tell. At present, it is compatible with the 20th edition of The Bluebook, but one of its goals is improvement that may mean breaking free of The Bluebook and making a more sensible, flexible system of citation for the United States. Can it succeed? Can it break The Bluebook’s dominance, as others have tried to do? Only time will tell.

Because Florida has its own Uniform Citation System in Rule 9.800, all Florida lawyers and judges should be abiding by it. When Rule 9.800 falls short in its guidance, then The Bluebook and Florida Style Manual should be referred to, in that order, under the current law. Since the ALWD Guide to Legal Citation and The Indigo Book are compatible with The Bluebook, they may be easier-to-use guides, and, as stated above, The Indigo Book is available free online. Introduction to Basic Legal Citation, which is also online, with its cross-references to The Bluebook, may be all you need as a practicing lawyer who cites mainstream authorities. I encourage you to check out the different guides and find the one that works best for you and your practice. Happy citing!

1 1 Florida Rules of Court, State at 940-41 (2016 revised ed.).

2 The Florida Bar, Florida Rules of Appellate Procedure 167-72, available at

3 “Except for citations to case reporters, all citation forms should be spelled out in full if used as an integral part of a sentence either in the text or in footnotes.” Fla. R. App. P. 9.180.

4 “Abbreviated forms as shown in this rule should be used if the citation is intended to stand alone either in the text or in footnotes.” Fla. R. App. P. 9.180. Those abbreviations include Ass’n, Co., Corp., Dep’t, Educ., Elec., and Ins. See Fla. R. App. P. 9.800(d)(1), (d)(2), (d)(4) & (l). Plus, all the rules of procedure, bar rules, and jury instructions have accepted abbreviations, such as Fla. R. Civ. P. 1.180, Fla. Admin. Code R. 62D-2.014, and Fla. Std. Jury Instr. (Civ.) 601.4. See Fla. R. App. P. 9.800(i).

5 See Fla. R. App. P. 9.800(o).

6 See Fla. R. App. P. 9.800(p). Website developer Matthew Butterick recommends never underlining because “[i]t’s ugly and makes text harder to read.” Matthew Butterick, Typography for Lawyers 78 (2010). Butterick prefers bold or italic, which are now readily available options that did not previously exist in the era of typewriters. The current trend is toward italics, which avoids the confusion in electronic publications where underlining signals a hyperlink.

7 You can see all the proposed amendments on the Florida Supreme Court’s website, which provides easy access to all the rules cases. See In re: 2017 Regular-Cycle Report for Amendments to the Florida Rules of Appellate Procedure, Case No. SC17-152.

8 Elevation of the Florida Style Manual above The Bluebook makes sense for Florida materials, but its lack of guidance for citing electronic sources means you will still need The Bluebook or some comparable citation manual.

9 Bryan Garner, The Bluebook’s 20th Edition Prompts Many Musings from Bryan Garner, ABA J. (Aug. 1, 2015).

10 Preface, The Bluebook: A Uniform System of Citation VII (20th ed.).

11 Id.

12 See, e.g., Alena Wolotira & Ambrogino Giusti, Differences Between the 19th and 20th Editions, Bluebook 101, University of Washington, Gallagher Law Library Guides,; Clare Willis, New Bluebook: A Call for Honest and Accurate Citation, IIT Chicago-Kent Law Library Blog (June 23, 2015),

13 The Columbia Law Review Association, Inc., The Harvard Law Review Association, the University of Pennsylvania Law Review & The Yale Law Journal Company, Inc., The Bluebook, Online Portal,

14 See Susan W. Fox & Wendy S. Loquasto, The Art of Persuasion Through Legal Citations, 84 Fla. Bar. J. 4 (April 2010), available at /divcom/jn/jnjournal01.nsf/Author/A8B63DC72FCE7882852576F10068ECD6.

15 Bryan Garner, The Bluebook’s 20th Edition Prompts Many Musings from Bryan Garner, ABA J. (Aug. 1, 2015), available at

16 Carol M. Bast & Susan Harrell, Has the Bluebook Met Its Match? The ALWD Citation Manual, 92 Law Libr. J. 337, 341-42 (Summer 2000).

17 Florida State University Law Review, Florida Style Manual iv (7th ed. 2010).

18 Id.

19 Id. at iii.

20 Id. at v.

21 See id. at §§3.1-3.12.

22 See id. at §§4.1-4.9.

23 Florida State University Law Review, Florida Style Manual (7th ed. 2010). Contact Journal Manager Lori Winfield at 850-644-2045 to order a bound volume or visit the iTunes App Store at to purchase the mobile version.

24 Carol M. Bast & Susan Harrell, Has the Bluebook Met Its Match? The ALWD Citation Manual, 92 Law Libr. J. 337, 339-40 (Summer 2000), available at

25 Darby Dickerson, Ass’n of Legal Writing Directors, ALWD Citation Manual: A Professional System of Citation (2000).

26 Coleen M. Barger, ALWD Guide to Legal Citation (5th ed.), can be purchased for $52 from Aspen or for lesser amounts, depending upon availability, from Association of Legal Writing Directors, ALWD Guide to Legal Citation,

27 Peter W. Martin, Introduction to Basic Legal Citation (Online Ed. 2016), Cornell Univ. Law School Legal Information Institute,

28 Cornell Law School, Peter Martin Publishes Latest Edition of Introduction to Basic Legal Citation (Jan. 11, 2016),

29 Introduction, The Indigo Book 8, available at

30 Id.

Wendy S. Loquasto is the managing partner of the Tallahassee office of Fox & Loquasto, P.A., a boutique appellate practice law firm. She is board certified in appellate practice and is a former chair of the Appellate Court Rules Committee. She received her J.D. from Stetson University College of Law.

This column is submitted on behalf of the Appellate Practice Section, Duane Daiker, chair, and Brandon Christian and Thomas Seider, editors.

Appellate Practice