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Blog/Bluebook rules

Bluebook signals: see, see also, cf., but see, e.g.

September 21, 20263 min readChecked against the Bluebook, 22nd ed. (2025)

On this page

  1. 1What each signal means
  2. 2The three mistakes
  3. 3Questions people ask
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A claim card on the left joined to five authority cards by lines of different kinds: solid for direct support, dashed for analogy, a crossed line for contradiction.

What each Bluebook signal tells the reader, which ones must carry a parenthetical, and how they are punctuated and ordered.

On this page⌄
  1. 1What each signal means
  2. 2The three mistakes
  3. 3Questions people ask

What each signal means

A claim connected to authorities by lines: no signal and see run straight to support, see also adds support, cf. runs dashed by analogy, but see runs the other way with a cross through it, e.g. fans out to many.
A signal says how the authority relates to your sentence. No signal means it says exactly that; see means it supports it; cf. means it is analogous; but see means it cuts the other way.
SignalThe authority…ParentheticalExample
No signalStates the point, or is the source of the quotation.Not requiredAnderson, 477 U.S. at 248.
E.g.,States the point, and so do others you are not listing. Attaches to any signal.Not requiredE.g., Anderson, 477 U.S. at 256.
AccordAlso states the point, after another authority was quoted or named for it.Not requiredAccord Celotex, 477 U.S. at 322.
SeeSupports the point without stating it.Not requiredSee Celotex, 477 U.S. at 323.
See alsoAdds support after the main authority has been cited.RequiredSee also Anderson, 477 U.S. at 252 (requiring more than a scintilla).
Cf.Decides a different question whose reasoning carries over.RequiredCf. Iqbal, 556 U.S. at 678 (disregarding conclusory allegations).
Compare … withTwo similar authorities, read together, make the point.Required, on eachCompare Twombly, 550 U.S. at 570 (requiring plausible facts), with Iqbal, 556 U.S. at 684 (applying it to every civil action).
Contrast … withTwo differing authorities, read together, make the point. New in the 22nd edition.Required, on eachContrast Conley, 355 U.S. at 45 (any set of facts), with Twombly, 550 U.S. at 563 (retiring that test).
ContraStates the opposite.Not requiredContra Twombly, 550 U.S. at 563.
But seeSupports the opposite without stating it.Not requiredBut see Iqbal, 556 U.S. at 678.
But cf.Supports something analogous to the opposite.RequiredBut cf. Matsushita, 475 U.S. at 587 (requiring a plausible inference).
See generallyGives background, not authority for the point. The one signal that needs no pincite.RequiredSee generally 10A Wright, Miller & Kane, supra, § 2727.
The twelve signals of Rule 1.2, in the order Rule 1.3 runs them. “Not required” is the floor: add a parenthetical whenever the reason for the citation would not otherwise be clear.

The three mistakes

No comma after a signal. E.g. is the exception: a comma follows it, and one precedes it when it joins another signal.

Wrong
See, Anderson, 477 U.S. at 248.
Right
See Anderson, 477 U.S. at 248. See, e.g., Celotex, 477 U.S. at 323.

See also, cf. and but cf. carry a parenthetical saying why the authority is there. Write it as a present participle, with no period inside.

Wrong
Cf. Iqbal, 556 U.S. at 678.
Right
Cf. Iqbal, 556 U.S. at 678 (disregarding conclusory allegations).

Signals run in the order shown above, and a signal of another kind starts a new citation sentence: a but see after a see follows a period, capitalised. Authorities under one signal are separated by semicolons.

Wrong
See Anderson, 477 U.S. at 248; but see Iqbal, 556 U.S. at 678.
Right
See Anderson, 477 U.S. at 248. But see Iqbal, 556 U.S. at 678.

In a court document the signal is italicised, capitalised when it opens a citation sentence, and lowercase inside a clause. Only the first negative signal keeps its but: but see and but cf. together are but see …; cf. ….

Questions people ask

What is the difference between see and see also?
See introduces an authority that supports the point without stating it. See also adds further support after the main authority has already been cited, and under the 22nd edition it carries a parenthetical saying what the added authority holds.
Do you put a comma after see?
No. The citation follows the signal directly. E.g. is the exception: E.g., Anderson, or See, e.g., Anderson.
When do you use cf.?
When the authority decides a different question but its reasoning supports yours by analogy. Say what the analogy is in a parenthetical; a bare cf. leaves the reader to guess.

How Counselcite helps

Counselcite reads each signal with the citation after it: it flags a comma after see, a cf. with no parenthetical, signals out of order, and a run-on across two families, and names the rule beside each.

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