Use parentheses for the prior history
Warning2Federal courts, Illinois courts21st and 22nd editions
Prior history goes in parentheses after the citation; the same phrase after a bare comma says instead what a later authority did to this one.1
- 1R. 12.7.4 Prior History. Tables: R. 12.8 Explanatory Parenthetical Phrases; T8 Explanatory Phrases.
- 2A warning: the form is usually wrong under the rule in note 1, and context can justify it.