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Bluebook Citation: Parentheticals

Bluebook Quick Reference

B10.1.5 (p. 15):  Weight of Authority and Explanatory Parentheticals.

B10.1.5 (p. 15):  Explanatory Parentheticals.

Rule 1.5 (p. 64):  Rule for Parenthetical Information.

Rule 10.6.1 (p. 107):  Rule for Weight of Authority Parenthetical.

Rule 10.6.3 (p. 108):  Rule for Order of Parentheticals.

Parentheticals Checklist

A handy reference for determining when and how to use parentheticals:

  • Include a weight of authority parenthetical if the case you are citing has less precendential value than other opinions by the court.
  • Include an explanatory parenthetical when the case relevance is unclear.
  • If both types of parentheticals are needed, cite the weight of authority parenthetical first.
  • If the citation also includes prior and subsequent case history, include this after the parenthetical.
  • Put the period closing the citation outside of the closing parentheses.

The Basics

Citation parentheticals allow you to give the reader important information in a very concise manner.  There are two types of parentheticals:

  1. Weight of Authority:  gives the precendential value of a cited case (only used for cases!).  Refer to Rule 10.6.1 for detailed guidelines.  However, this type of parenthetical is generally used in communicated two types of information:
    1. By looking at the weight (or relevance) of the authority (i.e. en banc, per curiam, etc.)
    2. By looking at the opinion description (whether or not there was a majority decision in the court). Include this is there are dissenting judges.
  2. Explanatory Parenthetical:  provides information about the authority without the need for a detailed explanation in the text.  Refer to Rules 1.5 and 12.7 when using an explanatory parenthetical.  The basic rule is that explanatory phrases begin with the present participle of the verb (ending in -ing).  Be as concise as possible.

Generally, the parenthetical is placed after the date of the decision in the citation.  

Multiple Parentheticals

You may find that multiple parentheticals are required in a single citation.  If parentheticals alone are needed (refer to the box above to determine when and what type are needed), place the parentheticals after the date of the decision just as you would with a single parenthetical.  In general, the order of parentheticals will be:

  1. Weight of Authority Parentheticals,
  2. "Quote" Parentheticals,
  3. Explanatory Parentheticals.

Refer to Rule 10.6.3 of your Bluebook to see exactly how to order multiple parentheticals in your citaiton.  

If there is a subsequent history or related authority component to the citation, place these after the parenthetical(s) in the citation sentence.

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