II. Case Citation Form
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Parenthetical Explanations (See Bluebook R. 1.5)

Information may be enclosed in parentheses after the basic citation when useful or when recommended because of the signal used. Brackets are not to be used. Explanatory parenthetical phrases should begin with a present participle, should not begin with a capital letter, and a period should be placed outside of the parenthetical explanation.

See Flanagan v. United States, 565 U.S. 259, 264 (1999) (explaining final judgment rule).

If the parenthetical information quotes one or more full sentences or a portion of material that reads as a full sentence, it should begin with a capital letter and include appropriate closing punctuation.

See id. at 267 ("A final judgment is not present in this case.").

Parentheticals should immediately precede any citation to subsequent history or other related authority. Thus, in the following example, the Eighth Circuit, not the Supreme Court, was discussing potential mootness:

Flanagan v. United States, 124 F.3d 128, 132 (8th Cir. 1998) (discussing potential mootness), aff'd, 465 U.S. 259 (1999).

Brief explanatory parentheticals may not always require present participles. (See I.E., I.F.).

"Drugs are deadly." Johnson v. Duer, 528 U.S. 192, 198 (1999) (per curiam) (emphasis added).