Citing to the Record in Briefs

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Category: Legal Writing, Public

My students are currently finishing up their briefs on summary judgment. We have been discussing the importance of citing to the court filings in a summary judgment motion setting. Here are the major rules from the 19th edition of the Bluebook regarding record citation. “B” here refers to the rules from the Bluepages at the beginning of the Bluebook.

B7.1.1—Abbreviation in General

When citing to other court filings in the same case, abbreviate the titles of those documents and cite a paragraph or page within the document. The 19th edition of the Bluebook permits a writer to choose to enclose the cite in parentheses or not. For now, my preference is to use the parentheses. (What do readers think about this change in form?)

Example: (Jefferson Aff. ¶ 2.) or Jefferson Aff. ¶ 2.

Cites to the record use an “R. at page number” format. Example: R. at 5. or (R. at 5.)

If the citation refers to the entire sentence, it comes after the period in the sentence. Place a period before the end parenthesis.

Refer to B7.1.4 regarding citation with PACER/ECF.

Example: The Plaintiff was driving a blue Ford. (Williams Aff. ¶ 7.)

If the citation only refers to part of the sentence, place the citation within the sentence immediately after the fact supported by the cite. Assuming the sentence contains two cites, place the period for the second citation after the parenthesis to emphasize that the second cite refers to the latter half of the sentence.

Example: Jones was in studying in Chicago (Jones Aff. ¶ 6), and Carson was visiting South Dakota (Carson Aff. ¶ 8).

Example 2: Smith did not observe anything unusual that day (Smith Aff. ¶¶ 2-3), and he received no phone calls from Jones (Jones Aff. ¶ 10). Notice the hyphen in this example to show citation to consecutive paragraphs.

BT.1: Abbreviating Titles of Court Documents

This list should be used in conjunction with B7.1.1 to abbreviate titles of court documents.

Words of more than six letters may also be abbreviated, even if the words do not appear in the list.

Omit articles and prepositions.

Other words in a document title may be omitted if the document can be unambiguously identified.

B7.1.2—Pinpoint Citations

Use a page, paragraph, or line as a pincite (do not use p. before a page number). Separate line and page references with a colon.

Other subdivisions such as paragraphs should be identified. Per Bluebook Rule 3.3(c), use more than one paragraph symbol to indicate multiple paragraphs. Do not put a space between the two symbols (see examples above).

It’s customary to use “at” with appellate record cites, but the 19th edition does not require “at” with other page number references in record cites.


Use a date to emphasize a significant date or when documents are otherwise indistinguishable, such as when the same person has provided multiple affidavits.

Example: (Elliot Aff. ¶ 7, March 9, 2012) and (Eliott Aff. ¶ 6, March 29, 2012)

B7.2—Short Forms

Use short forms as applicable after the long form is first given.

The Bluebook allows the use of id. with record cites. Id. should be underlined or italicized consistently with other cites in the brief.

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13 Responses to “Citing to the Record in Briefs”

  1. Natasha Baker-Bradley Says:


    Thank you for this helpful blog giving further clarification on the Bluebook.

    I recently had a disagreement with a coworker about the use of punctuation preceeding record citations in a compound sentence with compound citations (as in your “Jones lived in Chicago…” example above). While I agreed with your lack of commas preceeding the parantheses, my coworker did not, which led us to emailing the editors of the Bluebook to settle the issue.

    I thought you would like to know, so that your blog can be as accurate as possible, that the editor responded to me saying that he recommends the use of commas to offset the record citation in a compound sentence. For example: Jones went to school in Chicago, (R. at 5), but lived in Wisconsin, (R. at 8).

    Keep up the good work!


  2. anne moorman reeves Says:

    I continue to advocate the no-preceding-comma position, because enclosing the record reference in commas, while far better than only one comma before the reference, leaves the reader confused about whether the reference applies to the preceding info or the following info. By using only the comma following the page reference, it’s entirely clear that it belongs with the preceding text. Furthermore, what is in parens is parenthetical, meaning it can be removed without altering the sense of the text. Remove the R reference in the editor’s usage above leaves two commas separating the parts of the “Jones went to school” sentence.

  3. Now that The Bluebook allows the use of Id. for citations to the record, should Id. be in parentheses?

    (Tr. 45.) Is the short form Id. or (Id.)?

    Does it make a difference if the short form is Id. at 34?

  4. Melissa Greipp Says:

    The Bluebook now makes it optional to use parentheses around your record cites. If you are using parentheses around your record cites, then you use them with all record cites, including those that contain Id. For example, the basic Id. cite would look like this: (Id.) I don’t think it would make a difference if you changed the pincite, so in your example: (Id. at 34.)

  5. Is there a rule dictating that the period before the end of the parentheses? That is, why is it “(R. at 8.)” instead of “(R. at 8).”?

  6. Melissa Greipp Says:

    The difference between (R. at 8.) and (R. at 8). is that the former is a citation sentence form, where the citation comes after the sentence you’ve written, standing alone as a cite to the entire sentence. The period on the outside, as in the latter example, is appropriate in a citation clause format where you cite in two different places in a sentence. In that case, the period on the outside of the second citation clause signifies that the cite applies just to the second half of the sentence.

  7. Mike Tripp Says:

    Where an appeal arises from a grant of summary judgment, does the citation to the record in the statement of facts cite to the original source (e.g., affidavit) or to an admitted statement of fact?

  8. Melissa Greipp Says:

    I would recommend citing to the original source of a fact, such as an affidavit.

  9. This is very helpful to me. I am presently the Plaintiff and Pro Se litigant in 7th Dist. Ct, Chicago against IAMAW, Local 141(they have more money than the Vatican), “Breach of DFR”. I was fired from United Airline after 25 years, a co-worker pushed me in front of an aircraft that I was guiding to a gate. I am drowning but I must go on; I am the gate of Summary Judgment, my opposing response is due next Monday. For over 6 Months, the Judge has refused to appoint me an Attorney. On 8/4/15 he appointed me an attorney, the attorney did not get the message until 8/13 and I was just notified that the attorney has filed a motion for relief from assignment due to conflict of interest. His law firm is representing United as a non-party. I just filed a motion for an extension. The Local Rules are really difficult to navigate. Your article helped me in preparing my response. If you have the time take a look at Lionell Kline v. IAMAW District 141, IAMAW Local Lodge 1487 No. 14 CV 6369. The crux is United lied about video footage, when the video was finally located by a State agency, United had manipulated the footage, changed the images and really tampered with the images. The union still will not admit that the video exist. Thank for your guidance.

  10. Steve Mealor Says:

    Where do I put the period when there are additional parentheses in a citation sentence? If I follow the rule it looks like this: (Pl.’s Br. 6 (citing 42 U.S.C. 401(g)).) or (Doc. 56-2, Miller Contract (b).)


  11. Melissa Greipp Says:


    Your examples are correct. This is much like a full-sentence quote in a parenthetical cite to a case where you put the period to the sentence inside the end parenthesis and then add another period at the end of the citation.

  12. Mark Ballenger Says:

    I believe putting the parentheses around citations makes for easier reading.

  13. Mark Ballenger Says:


    Parentheses are used to refer to material that is not essential to the meaning of the sentence, without the parentheses the sentence would still make sense.

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