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Bluebook Citation: Parallel Citations

Bluebook Quick Reference

BT.2 (p. 30):  Local rules for citation and style.

Rule 10.3.1 (103): Rule for parallel citing and which source to cite.

Rule 10.3.3 (p. 104):  Public domain format rules.

T1.3 (p. 242):  Citation style for reporters.

Parallel Citation Checklist

Handy reference for deciding where and when a parallel citation should be used:

If you are NOT citing a state case, don't worry about a parallel citation

If you are citing a state case, but NOT to a state court in that same state, don't worry about a parallel citation.

If you are citing a state case that IS from a state court in the same state, you will need a parallel citation.

  • Refer to T1.3 to determine which reporters to cite.
  • List the state reporter before the regional reporter.
  • Only include the state abbreviation if the name of the state is not obvious in the reporter abbreviation.
  • Only include the abbreviation for the court if it is not the highest court in the state.

If you are citing a state case that IS from a state court in the same state, and uses the public domain format, you will need a parallel citation.

  • List the public domain citation before the regional reporter (if one is available).
  • Omit the court and date parenthetical.

The Basics

Parallel citations are used when the same case is printed in two or more different reporters.  In other words, a parallel citation references location information for more that one source of a case.  Rules 10.3.1 and 10.3.3 illustrate when and how to use a parallel citation.

The two major instances in which a parallel citation may be needed are:

1.  If there is a state reporter that prints the case in addition to a regional reporter, cite both the state and regional reporters (Rule 10.3.1).  Cite the state reporter first, then the regional reporter.

or

2.  If the citation is in public domain format, give both the public domain citation and the regional reporter citation (Rule 10.3.3).  Put the public domain citation first, then the regional reporter citation.

DO NOT include a parallel cite if:

1.  The case will be filed with a federal court.

or

2.  The case was filed with a court outside of the state.  In this case, only cite to the regional reporter.

Tutorials

Elon Law Library has a video tutorial that will walk you through the rules regarding parallel citations.  Please watch the video to better familiarize yourself with parallel citations.

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