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Blog/Bluebook rules

The 10 most common Bluebook citation mistakes

September 20, 20263 min readChecked against the Bluebook, 22nd ed. (2025)

On this page

  1. 1The ten
  2. 2Four that need explaining
  3. 3Questions people ask
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A citation drawn as a row of shapes on a page, with a few parts slightly out of place and a proofreader's caret in blue inserting the missing comma after the case name.

The ten Bluebook errors that appear in most briefs: the wrong form, the right form and the rule for each. Check a citation against them in a minute.

On this page⌄
  1. 1The ten
  2. 2Four that need explaining
  3. 3Questions people ask

The ten

Most citation errors in a filed brief come from about ten rules, the ones every citation meets: the pincite, the parenthetical, the short form, the signal. The example throughout is Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986).

MistakeWrongRightRule
Page span repeats digits247-248247-483.2(a)
No pincite477 U.S. 242 (1986)477 U.S. 242, 248 (1986)3.2(a)
Comma before the parenthetical242, 248, (1986)242, 248 (1986)10.5
Court the reporter already names(U.S. 1986)(1986)10.4
Court missing from a regional reporter162 N.E. 99 (1928)162 N.E. 99 (N.Y. 1928)10.4
Case name abbreviated in a sentenceIn Palsgraf v. Long Island R.R. Co., the court…In Palsgraf v. Long Island Railroad Co., the court…10.2.1
Short form without the reporterAnderson at 250Anderson, 477 U.S. at 25010.9
Id. after a string citeAnderson, 477 U.S. at 248; Celotex, 477 U.S. at 322. Id. at 323.… Celotex, 477 U.S. at 323.4.1
Comma after a signalSee, AndersonSee Anderson1.2
Italics past the case nameAnderson v. Liberty Lobby, Inc., 477 U.S. 242Anderson v. Liberty Lobby, Inc., 477 U.S. 242B2
Each rule links to its page in the rule library, with the check that catches it.

Four that need explaining

In a citation, the words in Table T6 are abbreviated (Railroad → R.R., Company → Co., Association → Ass'n). In a textual sentence, only the eight short words are: &, Ass'n, Bros., Co., Corp., Inc., Ltd., No.

The parenthetical names the court only when the reporter does not. U.S. Reports is the Supreme Court, so the year stands alone; F.4th could be any circuit, so the circuit goes in: (6th Cir. 2021). A state's highest court is not named — (N.Y. 1928), not (N.Y. Ct. App. 1928) — and the state is left out when the reporter gives it away.

Wrong
Palsgraf v. Long Island R.R. Co., 162 N.E. 99 (N.Y. Ct. App. 1928).
Right
Palsgraf v. Long Island R.R. Co., 162 N.E. 99 (N.Y. 1928).

When a citation carries more than one parenthetical, the order is fixed: the date, then the weight of authority, then a “quoting” or “citing” parenthetical, then the explanation.

Wrong
Anderson, 477 U.S. at 268 (arguing that the standard is unworkable) (Rehnquist, J., dissenting).
Right
Anderson, 477 U.S. at 268 (Rehnquist, J., dissenting) (arguing that the standard is unworkable).

A statute takes the section symbol with a space after it, is never italicised, and under the current edition a U.S. Code citation carries no year.

Wrong
42 U.S.C. §1983 (2018)
Right
42 U.S.C. § 1983

Questions people ask

How do you write a page range in a Bluebook citation?
Drop the digits the two page numbers share and keep at least the last two: 247-48, 1147-48, 305-06. Pages that are not consecutive are separated by commas: 247, 250.
Do you need a pincite in every case citation?
Yes, whenever you cite a case for something it says. A citation without one is proper only when you refer to the case as a whole.
Is the “v.” in a case name italicized?
In a court document the whole case name is italicised or underlined, including the v. The italics stop before the comma; the volume, reporter and parenthetical are roman.
Does a U.S.C. citation need a year?
No. Under the current Bluebook a citation to the United States Code takes no date: 42 U.S.C. § 1983. State codes cited to a bound volume still give the year on the volume.

How Counselcite helps

Counselcite checks a brief against all ten and about a thousand more rules, names the rule beside each finding, and writes the corrected citation over the old one. It also looks every case up in the public court record, which catches the one mistake no table can: a citation in perfect form to a case that does not say what the brief says.

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How to cite a case in Bluebook format

The six parts of a Bluebook case citation, what goes in the parenthetical for each reporter, and the short form, with examples.

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A citation drawn as its parts: a slanted bar for the italic case name, a comma, hairline boxes for the volume, reporter and page, one box in blue for the pincite, and a parenthetical at the end.

Case verificationSeptember 21, 2026

What courts did to lawyers who cited cases that do not exist

Sixteen sanctions orders from 2023 to 2026: the court, what was cited, what it ordered and the rule it used. And how to check that a case exists before you file.

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A ledger of citations on a white sheet, each row with a filled check mark, except one row drawn faint with an empty circle where its mark should be.
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