Lowercase the signal
Error2Federal courts, Illinois courts21st and 22nd editions
A citation set off by commas inside a sentence is a citation clause, and the signal opening one stays lowercase; only a signal opening its own citation sentence is capitalized.1
- 1B1.1 Citation Sentences and Clauses; B1.2 Introductory Signals; R. 1.1(b)(ii) Citation clauses.
- 2An error: the rule in note 1 allows one form, and this is not it.