My first-year law students are beginning to learn about legal citation. Today we discussed a question that sometimes causes confusion: whether to abbreviate the first word of a case name. The answer requires a student to synthesize a few rules from the Bluebook.
Bluebook Rule 10.2.2 states that all words listed in Table 6 (the table of abbreviations) must be abbreviated, even the first word in a party name. Table 6 notes that a word of eight letters (or more) may be abbreviated at the author’s discretion if substantial space is saved. Abbreviated words are punctuated by a period, unless the abbreviation is formed with an apostrophe (Corp., but Ass’n).
However, Rule 10.2 distinguishes case abbreviations in text from those in a stand-alone citation sentence. In text means that the citation appears within the sentence the student is drafting about the law, application, etc. Rule 10.2 provides that in text, words that would otherwise be abbreviated under Table 6 are not abbreviated. This is true whether it’s the party’s first name, or regardless of the placement of the name in the sentence (beginning, middle, end).
Finally, Rule 10.2.1(c) comes at the question from the angle of what words must always be abbreviated in text. It states that only “widely known acronyms” (such as CIA, FDA, per Rule 6.1(b)) and eight words (&, Ass’n, Bros., Co., Corp., Inc., Ltd., and No.) are to be abbreviated. A further exception, though, is that the eight words are not to be abbreviated if they begin a party’s name.
So, the short answer is “it depends.” If the case is cited in text, the first word would never be abbreviated, unless it’s a widely known acronym. If the case is cited as a citation sentence, then the first word would always be abbreviated if it’s found in Table 6 or is a widely known acronym, and you may choose to abbreviate a word of eight or more letters.