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 | Using id. |
| Non-consecutive authorities |
| Parallel citations |
| Using supra |
Using id. (and deciding when not to use id.)
First, a quick review of the short form id. The short form id. (you can either underline it or use italics) is an abbreviation for the Latin word "idem," meaning "the same." Since it's an abbreviation, it must always have a period. (Note: if you're underlining, underline the period, too!)
Id. is the short form to use when the citation refers to the same thing you cited in the very last citation--as long as that citation referred to only one source. You're telling the reader to look at that source again, whether it's a case, a statute, a book, or an article; the kind of authority doesn't matter. You can use id. to refer to any of them.
Capitalize id. when it begins a citation sentence. Do not capitalize id. when you use it in a citation clause.
When the citation to your source hasn't changed in any way, you need not say anything more than id. When the source is one that uses page numbers, and the page number is different from the page you just cited, no problem! You can still use id., but add the preposition at (not underlined or italicized) and the new page number (also neither underlined nor italicized; remember, id. is the only foreign word here). When the source uses a different sort of sub-unit, like a section or paragraph, indicate a different section or paragraph by citing the new sub-unit after id.
Here are some examples:
Full citation: McDonald v. Eubanks, 731 S.W.2d 769, 770 (Ark. 1987).
Short form still citing page 770: Id.
Short form now citing page 771: Id. at 771.Remember, you can use id. for any kind of authority. Here's an example of id. with a statute:
Full citation: Ark. Code Ann. § 9-12-312(a) (1991).
Short form for same section: Id.
Short form for different section: Id. § 9-12-312(c).You cannot use id. if the preceding citation refers to more than one source. Typically, a multi-source citations is a string citation (two or more citations, connected by a semi-colon). In this situation, follow the short form rules for non-consecutive authorities, set out below.
If you need more specific help with id. (for example, when you're working with an authority other than cases or statutes), check the ALWD Citation Manual or the Bluebook. At the end of the manual's section describing citation rules for each type of authority, you'll find reference to creating short forms for that kind of authority.
What do you do when you can't use id.?
You'll have to provide the reader with a bit more information, but still not nearly as much as the full citation provided. The idea is to give the reader enough information to easily retrieve the cited source from the stack of books on the desk or from the electronic database. That generally means, therefore, that you've got to provide information concerning the type of source and specific volume, in addition to the page number.
For cases, here are the basics:
| a party name (usually the first given, but it's your choice; many writers use the appellee if the name is more distinctive); |
| the volume number and reporter abbreviation; and |
| the specific page number(s). |
That's all. But that's enough. Ready for some examples?
Full citation: Lewallen v. Bethune, 593 S.W.2d 64, 66 (Ark. 1980).
Short form: Lewallen, 593 S.W.2d at 66.Full citation: Boykin v. Alabama, 395 U.S. 238, 244 (1969).
Short form: Boykin, 395 U.S. at 242.
BUT NEVER EVER CITE THIS WAY!!
Lewallen at 67.
Boykin at 241.What's the problem with these citations? They give the reader no indication which reporter, or which volume the case appears in.
return to topLegal writers generally use a parallel citation only where a local court rule or local custom demands that they do so. Because parallel citations are so long, short forms are particularly useful for authorities that you cite often. It is permissible to use id. for the first source in a parallel citation. It cannot, however, stand for both sources.
Here are some examples of short forms to Arkansas cases; imagine you're writing a brief to an Arkansas court:
Full citation: Capitol City Manor, Inc. v. Culberson, 1 Ark. App. 137, 139, 613 S.W.2d 835, 836 (1981).
Short form: Id. at 140, 613 S.W.2d at 837.If id. is not appropriate, because you have cited intervening authorities, follow this model:
Full citation: Arnold Fireworks Display, Inc. v. Schmidt, 307 Ark. 316, 319, 820 S.W.2d 444, 446 (1991).
Short form: Schmidt, 307 Ark. at 319, 820 S.W.2d at 445.
The short form supra is easily and often misused, to the great frustration of the reader who encounters it in a citation. The term supra simply means "above"; thus the short form simply tells the reader: "The full citation is somewhere up above, but I'm not telling you where!" The reader is then forced to read backwards through the document, looking for the elusive full citation to the authority. Not much fun.
According to the leading citation manuals, supra can only be used to refer to secondary authorities. This is a sensible rule. If you're citing a primary authority, its "primariness" makes it important enough that you should give the reader adequate information--on the spot--to easily locate the source. Secondary authorities, in contrast, never have any mandatory force, and presumably, readers can hunt for them or not, as they feel inclined.
Supra is truly only appropriately used when the document you are writing has footnotes and you wish to cite a source previously cited in full. In that instance, your citation can tell the reader exactly where, up above, to find the cited source. The reader still has to back up, but at least knows where to look. For example:
7Carter, supra n. 4, at 43-44.
The best rule of thumb is to write so that you can avoid using supra altogether. If the source is good enough for you to cite, why not help your reader find it easily when you cite it in short form? return to top
