Use the punctuation the phrase takes
Warning2Federal courts, Illinois courts21st and 22nd editions
An explanatory phrase that takes the citation as its direct object runs straight into it (“aff’g 435 F. Supp. 166”); every other phrase is followed by a comma (“aff’d, 123 F.3d 4”).1
- 1R. 10.7.1(a) Prior or subsequent history; R. 1.6 Related Authority; R. 15.5.2(a) Documents originally published. Tables: T8 Explanatory Phrases.
- 2A warning: the form is usually wrong under the rule in note 1, and context can justify it.
More in 10.7 Prior and Subsequent History