Abbreviate to "ex rel."

Error²Federal courts, Illinois courts21st and 22nd editions

A relator phrase such as "on the relation of" or "on behalf of" contracts to "ex rel." in a case name, matching the form courts expect in citations.¹

1. 1B10.1.1 Case Names. Tables: R. 10.2.1(b) Procedural phrases.
2. 2An error: the rule in note 1 allows one form, and this is not it.