II. Case Citation Form
. . .
B. Short Citation Forms (See Bluebook P. 4)
Once a full citation is given, you may use a short form for cases, statutes, regulations, legislative materials, books, articles, and periodical materials as long as (i) it will be clear to the reader from the short form what is being referenced, (ii) the earlier full citation falls in the same general discussion, and (iii) the reader will have little trouble locating the full citation quickly.
Citation to a case that has been cited in full in the same general discussion may be shortened to one of the following forms if the shortened citation clearly identifies the case. Note that the short forms listed below give only one or neither of the parties. Generally, the first party's name should be used for the short form; however, avoid using the name of a governmental or other common litigant to identify the case. Short forms do not give the first page of the case or the court or year of decision. They do, however, include the word "at" to indicate the page on which the specific material appears.
Proper short forms for State v. Calandra, 510 N.W.2d 338, 343 (N.D. 1995), include:
Calandra, 510 N.W.2d at 343.
510 N.W.2d at 343. [Use only when case name is underlined in text of sentence, not when referring to party generally.]
Id. at 343.
For cases in which a parallel citation to the North Dakota Reports is required,
Roe v. Doe, 79 N.D. 120, 121, 57 N.W.2d 230, 231 (1953).
Doe, 79 N.D. at 121, 57 N.W.2d at 231.
The id. form when a parallel citation to the North Dakota Reports is required is:
Id. at 121, 57 N.W.2d at 231.
For cases in which a parallel citation to a public domain source is required, short citation forms take a slightly different form. A parallel citation to the Northwestern Reporter is included, but only to the first page of the opinion because the paragraph number is found in both sources. Thus,
Smith v. Jones, 1997 ND 235, ¶ 34, 560 N.W.2d 890.
Smith, 1997 ND 235, ¶ 34, 560 N.W.2d 890.
The id. form where a parallel citation to a public domain source is required is:
Id. at ¶ 34.
"Supra," "Infra," and "Hereinafter": "Supra" or "infra" are not used as short forms for cases. "Supra" may, however, be used in short forms for books, treatises, etc. (See III.G.). The use of "Hereinafter" should be avoided. In a text sentence, a shortened version of a person's or business's name or other groups of words may be placed in parenthesis surrounded by quotation marks to identify how the person or business will subsequently be referred to. When citing books or treatises, but not cases, especially where there is no author and the title is long, a shortened version of the title may be placed in brackets and surrounded by quotations. (See III.F.)
"Id.": "Id." may be used as a short form, but only when it unambiguously refers to a source. If using "id." would be ambiguous, use a short form that also uses part of the case name. For example:
Contract interpretation is a matter of law. Smith, 414 N.W.2d at 128. This Court has previously discussed the application of N.D.C.C. § 9-06-07 in Jones v. Johnson, 274 N.W.2d 123 (N.D. 1978). Id.
The use of "id." would not be proper here, because "id." might refer to Smith or to N.D.C.C. § 9-06-07 or to Jones. If the citation were to Smith, then Smith, 414 N.W.2d at 128, would be the proper citation. If the citation were to Jones, no further citation would be necessary, because the citation is in the text.
"Id." should never be used to refer back to a string cite.
|improper:||The world is flat. Rider v. Johnson, 220 N.W.2d 123, 145 (N.D. 1965); Vespucci v. Columbus, 219 N.W.2d 12, 13 (N.D. 1964). The sky is blue. Id.|
|proper:||The world is flat. Rider v. Johnson, 220 N.W.2d 123, 145 (N.D. 1965); Vespucci v. Columbus, 219 N.W.2d 12, 13 (N.D. 1964). The sky is blue. Rider, 220 N.W.2d at 145; Vespucci, 219 N.W.2d at 13.|
When "id." is used with a signal, the "I" is not capitalized and the underline is not continuous.
See id. at 129.
But see, e.g., id.
Special short form--Where full form or full short form is in same paragraph: Often, "id." will not be available as a short form because another citation has been used in between the reference you wish to "id." to. Where "id." is not permissible, if--and only if--the full form or the full short form has previously been cited in the same paragraph, a short form, which retains only the first party's name, a comma, and the pin cite preceded by "at", may be used. Thus in the proper situation:
Smith v. Jones, 544 N.W.2d 123, 144 (N.D. 1994) becomes: Smith, at 144.
Abe v. Gabe, 1999 ND 11, ¶ 12, 599 N.W.2d 567 becomes: Abe, at ¶ 12.
The following example is correct:
Dogs are good pets. Fido, 1999 ND 123, ¶ 13, 600 N.W.2d 870. Snakes are not slimy. King, 487 N.W.2d at 356. Cats, however, make the best pets. Fido, at ¶ 15. Snakes are very easy to care for. King, at 357.