II. Case Citation Form
. . .
D. Signals (See Bluebook Rs. 1.2, 1.3)
When more than one signal is used, the signals should appear in the order listed below. Signals of the same basic type--supportive, comparative, contradictory, or background--must be strung together within a single citation sentence and separated by semicolons. Signals of different types, however, must be grouped in different citation sentences.
See Massachusetts Bd. of Retirement v. Murgia, 427 U.S. 307 (1976); cf. Palmer v. Ticcione, 433 F. Supp. 653 (E.D.N.Y. 1977) (upholding mandatory retirement age for kindergarten teachers). But see Gault v. Garrison, 569 F.2d 993 (7th Cir. 1977) (holding classification of public school teacher based on age violative of equal protection). See generally Comment, Application of Middle-Level Scrutiny to Old-Age Classifications, 127 U. Pa. L. Rev. 798 (1979) (advocating new approach).
Signals indicating support:
|[no signal]||Cited authority (i) identifies the source of a quotation, or (ii) identifies an authority referred to in text.|
|Accord||"Accord" is commonly used when two or more cases clearly support the proposition but the text quotes only one; the others are then introduced by "accord." Similarly, the law of one jurisdiction may be cited as being in accord with that of another.|
|See||Cited authority directly states or clearly supports the proposition.|
|See also||Cited authority constitutes additional source material that supports the proposition. "See also" is commonly used to cite an authority supporting a proposition when authorities that state or directly support the proposition already have been cited or discussed. The use of a parenthetical explanation of the source material's relevance is encouraged.|
|Cf.||Cited authority supports a proposition different from the main proposition but sufficiently analogous to lend support. Literally, "cf." means "compare." The citation's relevance will usually be clear to the reader only if it is explained. Parenthetical explanations, however brief, are therefore strongly recommended.|
Signal suggesting a useful comparison:
|Compare . . .|
|[and] . . .|
|with . . .|
|[and] . . .||Comparison of the authorities cited will offer support for or illustrate the proposition. The relevance of the comparison will usually be clear to the reader only if it is explained. Parenthetical explanations following each authority are therefore strongly recommended. If citing only one case use Cf.|
Compare Richardson-Merrell Inc. v. Koller, 472 U.S. 424 (1985) (discussing products liability law) with Firestone Tire & Rubber Co. v. Risjord, 449 U.S. 368 (1981) (applying Restatement of Torts) and Cobbledick v. United States, 309 U.S. 323 (1940) (holding manufacturer liable).
Signals indicating contradiction:
|But see||Cited authority directly states or clearly supports a proposition contrary to the main proposition. "But see" is used where "see" would be used for support.|
|But cf.||Cited authority supports a proposition analogous to the contrary of the main proposition. The use of a parenthetical explanation of the source material's relevance is strongly recommended.|
Signal indicating background material:
|See generally||Cited authority presents helpful background material related to the proposition. The use of a parenthetical explanation of the source material's relevance is encouraged.|
Combining a signal with "e.g.,":
"E.g.," can be used by itself, or in combination with any other signal, to indicate that other authorities also state, support, or contradict the proposition but that citation to them would not be helpful or is not necessary. A comma should always follow "e.g.". The comma is not underlined. If "e.g.," is used in combination, a comma should also follow the preceding signal. This comma is underlined, and the "e" is lower case.
But see, e.g.,
Signals used as verbs:
Signals may be used as the verbs of ordinary sentences, in which case they are not underlined. When signals are used as verbs, information that would be included in a parenthetical explanation should be made part of the sentence itself. "Cf." becomes "compare" and "e.g.," becomes "for example" when used in this manner.
Dogs may get one free bite. E.g., Cat v. Dog, 550 S.E.2d 123, 125 (Ga. 1990)
Some cases, for example, Cat v. Dog, 550 S.E.2d 123, 125 (Ga. 1990), have allowed dogs one free bite.