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Bluebook: Citation Signals1

The Basics
Citation signals are notoriously confusing. However, they can be
understood and used with a little bit of knowledge. Signals are used to
give the relationship of the source you are citing to your text, and how
that relates to other material in the citation sentence. In simpler terms, it
is kind of like a form of code that quickly conveys extra information to
the reader. Signals can be used with any type of authority, and the 11
signals can be organized into four groups based on relationship
information:

1. Those that show support (Supportive)


2. Those that suggest a useful comparison (Comparative)
3. Those that indicate contradiction (Contradictory)
4. Those that indicate background materials (Background)

As noted above, there are 11 signals that you can use. They are:

[no signal]: Use this when the cite directly supports the text, when
the source is a quote, or when you are directly referring to
something in your text. This is used when what you are citing is
clearly supporting the text.
E.g.: Meaning "for example", this is used to indicate that the
sources you are using are only a small representative of a larger
sample.
See: This indicates that the source you are using does not directly
state the proposition, but supports it.
See also: This can be used after a no signal cite to a "see" cite to
give additional authorities.
Accord: This is used when only one source is mentioned in the
text, but additional sources are being cited.
Cf.: Meaning to compare this is used when an authority doesn't
exactly support what you are saying, but still lends support to the
argument.

1
Mary Kilpatrick, Bluebook Legal Citation: Signals, Law Library, THE MASSACHUSETTS SCHOOL OF LAW (Jan. 24,
2014), http://mslaw.libguides.com/content.php?pid=500368&sid=4116739
Compare...with...: This contrasts two authorities that have
different views on what you are discussing.
Contra: This is used when the authority contradicts the
proposition.
But see: This is used when the authority contradicts the
proposition, but without being direct (implicitly).
But cf.: This is used when the authority contrasts the proposition
indirectly (by analogy).
See generally: This is used when your cited authority uses
background material to support your text

Supportive Comparative Contradictory Background


No signal Comparewith Contra See generally
E.g. But see
Accord But cf.
See
See Also
Cf.

To use a signal:

Capitalize your signal only if it begins a sentence.


Italicize the signal when it is used in the citation sentence.
Make sure to consult Rule 1.2 to ensure the proper use of a signal!

Multiple Signals
If you are using more than one signal, they should be ordered
accordingly:

1. [no signal]
2. E.g.,
3. Accord
4. See
5. See also
6. Cf.
7. Compare...with...
8. Contra
9. But see
10. But cf.
11. See generally.

In simpler terms, you can remember that signals are generally ordered
with supportive first, followed by comparative, then contradictory,
then background signals.
Additionally, you may have multiple authorities in a single signal. This
is known as a "string cite." Refer to Rule 1.4 to see the Bluebook
guidelines for ordering the authorities. In general, if one source is
considered more "authoritative" than the others, place this one first in
the string cite. Separate each authority with a semicolon.
Finally, there may be times when you will use a signal that could be
aided by the use of a descriptive parenthetical. There are general rules
for when to include a parenthetical with your signal, and these are
summarized in the table below:

No Parentheticals Parentheticals Parentheticals


Encouraged Strongly
Recommended
[no signal] See also Cf.
E.g., See generally Compare...with...
See But cf.
Accord
Contra
But see
As stated before, include the parenthetical at the end of the citation
sentence, after the date.
Ex: See also Jerome H. Reichman & Rochelle Cooper Dreyfuss, Harmonization without
Consensus: Critical Reflections on Drafting a Substantive Patent Law Treaty, 57 Duke L.J.
85, 98 (2007) (noting that the developing countries are being pressurized to provide
the higher, TRIPS-plus levels of intellectual property protection embodied in
bilateral or regional trade agreement).

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