Research Guides

Citing Sources: Indigo Book (Legal Citations)

A guide to major citation styles, and tips for writing & citing

Legal Citations: Indigo Book

About Legal Citations

There are several style manuals for legal citations, including the Bluebook, Indigo Book, and ALWD Guide. This guide uses the Indigo Book, which is an open access guide to uniform legal citation. The Indigo Book may be substituted for the Bluebook or ALWD Guide when you are doing legal citations. When in doubt, ask your professor or a librarian for more help! You might need to combine rules from the Bluebook and the Indigo Book to create a certain citation.

Why are legal citations so complicated?

Legal citations can be like reading a code. In order to know how to cite something, it is essential that you know the elements, or pieces, that make up a particular resource. These can be less familiar than those of other citation styles, with elements like party names, titles, courts, court reporters, and other technical legal jargon. Don't hesitate to reach out for help if it seems overwhelming!

How to Format Footnotes

A footnote consist of two parts:

  1. superscripted note number (1) in the text, placed at the end of a sentence or clause
  2. A footnote containing the citation, placed at the bottom of the page. The formatting of the text within the footnote depends on the type of legal document that you are citing.

1. Grutter v. Bollinger, 539 U.S. 306 (2003).

2. H.R.J. Res. 208, 92d Cong. (1971).

Footnotes can contain many things besides a simple citation. For example, they can have signals, multiple sources, explanatory parentheticals, and even additional sentences. This guide contains examples of each.


For more information, see The Indigo Book R4.

Signals appear in the footnote before the citation of the source. The signal itself is italicized, even if the other text in the footnote is not. They inform the reader how, exactly, the claim in their writing relates to the source cited in the footnote. There are four broad categories that signals can be grouped into: support, comparison, contradiction, and background materials.

Note that there are certain situations where you can omit a signal. This happens when:  the source in your footnote makes the same claim, you are directly quoting that source, or the source is 1) the source in your footnote makes the same claim as you, 2) you are directly quoting the source, or 3) you refer to the source in the text.

Supporting Authority

  • E.g.,
  • Accord
  • See
  • See also
  • Cf.


  • Compare XXX with YYY.

Contradictory Authority

  • Contra
  • But see
  • But cf.

Background Material

  • See generally

1. See Roe v. Wade, 410 U.S. 113 (1976). Contra Dobbs v. Jackson Women's Health Org., 142 S.Ct. 2228 (2022).

2. Compare Nancy Scherer, Diversifying the Federal Bench: Is Universal Legitimacy for the U.S. Justice System Possible?, 105 Nw. U. L. Rev. 587 (2011) with Janine Young Kim, Resistance and Transformation: Re-Reading Mari Matsuda in the Postracial Era; 18 Asian Pac. Am. L.J. 35 (2012).

Order of Authorities Within a Footnote: How to Organize Footnotes That Cite Multiple Sources

For more information, see The Indigo Book R10.

If you are citing multiple sources in one footnote, they should be separated by a semicolon. The order of the sources within each signal should be in order from the strongest authority to the lowest. However, if there is one source that is more helpful than the others, that source should be cited first. The order of authority is as follows:

  1. Constitutions (federal, state, foreign, IGOs)
  2. Statutes (federal, state, foreign)
  3. Treaties
  4. Cases (federal, state, foreign, international)
  5. Legislative materials
  6. Administrative and executive materials (federal, state, foreign)
  7. International Governmental Organization (IGO) documents
  8. Briefs and other court documents
  9. Secondary materials (books, law review articles, student-written law review articles, magazines/newspaper articles)
  10. Unpublished materials
  11. Websites


Short Forms: How to Cite the Same Source Again

For more information, see The Indigo Book R15 (cases), R22 (legislative and administrative materials), R26 (court documents), R29 (books), R31 (law reviews), or R34 (internet sources).

Once you have cited a source once, you can use a shorter version of that citation again throughout the rest of your assignment. Despite, or even because of, the length of legal documents, the citation styles call for shortening citations wherever you can! *Pro tip: wait until you have finished writing and editing your document to change your citations to their short forms. That way, if you move anything around, you won't lose track of which sources you are citing!


Id. is used when you are using the exact same source as the immediately preceding footnote. If you are citing the same source, but a different page or section number, note any changes to the page or section number in the following citation. Id. can be used for any type of source as long as it is the same exact source cited in the immediately preceding footnote.


1. Raquel Muñiz, Maria Lewis, Grace Cavanaugh & Melissa Woolsey, The Social Context of the Law: A Critical Analysis of Reliance Interests in the Department of Homeland Security v. Regents of the University of California, 95 S. Cal. L. Rev 857, 869 (2022).

2. Id. at 872.

3. Id.

4. Id. at 869.


Supra can be used once you have already cited the full source in a prior footnote. It acts as an internal cross-reference to the footnote that has the full citation of the document. Unlike idsupra can be used when the source you are citing is not in the immediately preceding footnote. However, supra can only be used for certain types of documents. You cannot use supra if you are citing cases, statutes, or legislative materials, but you can use it for books, hearings, court filings, treaties, regulations, law reviews, and reports.


1. Adam R. Chang & Stephanie M. Wildman, Gender In/Sight: Examining Culture and Constructions of Gender, 18 Geo. J. Gender & L. 43, 50 (2017).

2. Grimm v. Gloucester Cnty. Sch. Bd., 972 F.3d 586, 590 (4th Cir. 2020).

3. Id. at 592.

4. Chang & Wildman, supra note 1, at 50.

5. Grimm, 972 F.3d at 590.

How to Format the Bibliography

General Formatting of the Bibliography Entries

Good news - there is no bibliography required! If you are using The Indigo Book with another citation style, such as the Chicago Manual of Style, defer to that citation style's rules for bibliographies.

How do I deal with ___?

Missing citation elements

  • Author:
    • If no personal author is listed, determine whether an organization is responsible for the content. If so, use that organization's name as the author. (CMOS14.84)

      1. World Bank. Poverty and Social Exclusion in India(Washington, DC: World Bank, 2011), 15.

    • If the author is unknown, start the note and bibliography entry with the title. (CMOS14.79)

      2. "The Titanic Sails To-Day," New York Times, April 10, 1912.

  • Place: Use n.p. if it is unknown. If it can be surmised, put in brackets with a question mark. (CMOS14.132)
  • Publisher: If not listed on the title page or copyright page, use "self-published" or "printed by author." (CMOS14.137)
  • Date: When the date of a printed work cannot be determined, use n.d. For web pages, use the access date. (CMOS14.14514.207)
  • Page numbers: For unpaginated works, such as online resources, include a descriptive phrase using one of the divisions used in the work (chapter, paragraph number, section heading, etc.) in the notes. If the work is short, such locators may not be necessary. (CMOS14.22)

More than one author

  • List authors in order they appear on title page
  • In the bibliography, invert the first author's name only and place a comma before and after the first name
  • Use the word "and," not an ampersand (&)
  • For works with 4-10 authors, list all names in the bibliography, but only use the first author's name followed by et al. for the note.
  • For works with more than 10 authors, only include the first 7 authors and et al. in the bibliography


1. Gilbert Geis and Ivan Bunn, A Trial of Witches: A Seventeenth-Century Witchcraft Prosecution (London: Routledge, 1997), 17.

2. Chih-Hung Ko et al., "The Associations between Aggressive Behaviors and Internet Addiction and Online Activities in Adolescents," Journal of Adolescent Health 44, no. 6 (2009): 600.


Geis, Gilbert, and Ivan Bunn. A Trial of Witches: a Seventeenth-Century Witchcraft Prosecution. London: Routledge, 1997.

Ko, Chih-Hung, Ju-Yu Yen, Shu-Chun Liu, Chi-Fen Huang, and Cheng-Fang Yen. "The Associations between Aggressive Behaviors and Internet Addiction and Online Activities in Adolescents." Journal of Adolescent Health 44, no. 6 (2009): 598-605. 

Using a source quoted in a secondary source

It is always better to consult the original source, but if it cannot be obtained, cite the original source and the secondary source you used in the notes and the secondary source only in the bibliography (CMOS14.260):


1. Theodore Sedgwick, Thoughts on the Proposed Annexation of Texas to the United States (New York: D. Fanshaw, 1844), 31, quoted in Lyon Rathbun, "The Debate over Annexing Texas and the Emergence of Manifest Destiny," Rhetoric & Public Affairs 4, no. 3 (Fall 2001): 479.

Rathbun, Lyon. "The Debate over Annexing Texas and the Emergence of Manifest Destiny." Rhetoric & Public Affairs 4, no. 3 (Fall 2001): 459-493.

Examples: Court Cases

Court Cases

For more information see: The Indigo Book § B

Basic Format

1. Party 1 v. Party 2, [Volume number] [reporter] [first page], page you're citing to (court year) (explanatory parenthetical if necessary).



1. Lawrence v. Texas, 539 U.S. 558, 575 (2003) ("[T]he instant case requires us to address whether Bowers itself has continuing validity.") .

2. Brandt v. Rutledge, 47 F.4th 661, 672 (8th Cir. 2022).

Case Names

For more information see: The Indigo Book R11.2 and T11.

Case names can be very long. Legal writing prefers shorter citations, so there are many different rules to help shorten case names. For instance, certain words are abbreviated (see T11), procedural phrases are replaced or omitted (see R11.2.5), and first names are omitted (see R11.2.1). For the many nuances of case names, refer to the examples below, R11, and T11.


Correct: Awad v. Ziriax, 670 F.3d 1111 (10th Cir. 2012).

Incorrect: Muneer Awad v. Paul Ziriax, Agency Head, Oklahoma State Board of Elections, Thomas Prince, Chairman of the Board, Oklahoma State Board of Elections, Steve Curry, Board Member, Oklahoma State Board of Elections, and Jim Roth, Board Member, Oklahoma State Board of Elections, 670 F.3d 1111 (10th Cir. 2012).

Correct: Bd. of Educ. of Kiryas Joel Village Sch. Dist. v. Grumet, 512 U.S. 687 (1994).

Incorrect: Board of Education of Kiryas Joel Village School District v. Louis Grumet, 512 U.S. 687 (1994).

Volume Number, Reporter, First Page

For more information, see The Indigo Book R11.3.

The middle part of a case citation dates back to when cases were printed in physical collections called reporters. To locate a case in print, you would need the volume of the reporter, the name of the reporter itself, and then the first page on which the case appeared. So, it should look something like this:

[Volume #] [Reporter abbreviation] [First page # of the case], [Pincite, A.K.A. the actual page of the case that you are citing]. 

You can typically find this information at the top of a case, while the page numbers within the text of the case are usually preceded by a single *.


The first column contains information on the case written out, while the second column translates that information into a citation.

Location Information Citation
Moore v. Harper, which starts on page 2065 in volume 143 of the Supreme Court Reporter. Moore v. Harper, 143 S.Ct. 2065 (2023).                         
Huot v. City of Lowell, which starts on page 228 in volume 280 of the 3rd series of the Federal Supplement. We want to specifically to a quote on page 233. Huot v. City of Lowell, 280 F.Supp.3d 228, 233 (D. Mass. 2017).                                                                                                                     

Short Form for Cases

For more information. see The Indigo Book R15.

Once a case has been cited in full, you can use a short form version as long as it is unambiguous to which case you are referring. Remember, you can use Id. in certain circumstances. The short form of a case is typically Party 1, [volume number] [reporter] at [pincite - the actual page of the case you are citing.



1. Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah, 508 U.S. 520 (1993).

2. Id. at 528.

3. Lighthouse Fellowship Church v. Northam, 458 F.Supp.3d 418, 428 (E.D.Va. 2020).

4. Lukumi, 508 U.S. at 528.

5. Lighthouse, 458 F.Supp.3d at 428.



Examples: Legislative Materials


For more information, see the Indigo Book R16R17, and T3.


Federal statutes are comprised of the name of the statute, the source of publication, and either the year published or passed. If possible, cite to the official US Code (U.S.C.) rather than an annotated version, such as the U.S.C.A. or U.S.C.S.. The basic citation looks like: [name of statute], [title number] [publication] § [section number] ([year]).

State statutes generally include the same information: [name of state code] §[section number] ([year]). You can find the title and abbreviation of state publications in T3.


1. Respect for Marriage Act, 1 U.S.C. §7 (2022).

2. Me. Stat. tit. 19-A, §650-A (2011).

Federal Bills

For more information, see the Indigo Book R21


For federal bills and resolutions, include the name of the bill/resolution, abbreviation of the legislative body, legislature number, legislature name, section number, and the year of publication:

[Name], [Senate or House and number of the bill] [legislature number and name] § [section number if it's not the whole bill] ([year]).


1. Dream Act of 2021, S. 264, 117th Cong. § 4 (2021).

Examples: Regulations and Executive Materials


For more information, see the Indigo Book R19.


Executive branch agencies, such as the Department of Justice or the Environmental Protection Agency, create administrative rules and regulations to carry out the laws passed by Congress, as well as Executive Orders and other forms of law The final, codified versions appear in the Code of Federal Regulations, or C.F.R. Including the name of the regulation is optional. The format is as follows for the C.F.R.:

[Regulation name and/or agency name - optional], [title number] C.F.R. § [section number] ([year]).

If a regulation has not yet been codified, you can cite the Federal Register, which is published daily on weekdays and includes executive orders as well as proposed rules and regulations. If the Federal Register includes the future location of the rule or regulation in the C.F.R., include that in parentheses. If not, don't worry, just omit that portion of the citation. The citation is slightly different:

[Regulation name], [volume number] Fed. Reg. [first page number] ([full date]) (to be codified at [C.F.R. citation]).


1. 40 C.F.R. § 120.2 (2021).

2. National Priorities List, 87 Fed. Reg. 55299 (Sept. 9, 2022) (to be codified at 40 C.F.R. pt. 300).

Executive Orders

For more information, see the Indigo Book T2.


Generally, executive orders do not have names. Only use it in your citation if it would help readers more readily identify the order (for example, the Emancipation Proclamation). Like with regulations, cite to the C.F.R. rather than the Fed. Reg. if possible.

Exec. Order [number], [title or volume number] [C.F.R. or Fed. Reg.] [page number] ([date]).


1. Exec. Order 14008, 3 C.F.R. 477 (Jan. 27, 2021).

2. Exec. Order 13493, 74 Fed. Reg. 4901 (Jan. 22, 2009).

Examples: Articles

Law Review Articles

For more information, see the Indigo Book R30.

Law reviews are journals (a type of periodical) that are generally (but not always) edited and run by law students. The articles themselves, however, are mostly written by legal experts, scholars, and practitioners. They contain multitudes of citations, and can be very useful for research and locating additional sources. The title of the law review should be abbreviated using Tables T15 and T18. If there are two authors, separate the names with &. If there are more, use commas or "et al." after the first author. You do not need to include a URL.The general citation format is:

[Author first name] [last name], [title of article], [volume number] [name of journal] [first page], [page you're citing] ([year]).


1. Nancy Scherer, Diversifying the Federal Bench: Is Universal Legitimacy for the U.S. Justice System Possible?, 105 Nw. U. L. Rev. 587, 592 (2011).

2. Tara Leigh Grpve, Sacrificing Legitimacy in a Hierarchical Judiciary, 121 Colum. L. Rev. 1555, 1609 (2021).


For more information, see the Indigo Book R30R32, and T18.

If the magazine article is only available online, or you're using the online version, append the URL to the end of the citation. 

[Author first name] [last name], [title of article], [abbreviated name of magazine], [full date] [URL]. 


1. Kellie Carter Jackson, The Double Standard of the American Riot, Atlantic, June 1, 2020,


For more information, see the Indigo Book R30R32, and T18.

[Author first name] [last name], [title of article], [abbreviated name of newspaper], [full date] [URL or page number]. 

1. Coral Davenport, Biden Administration moves to Raise the Cost of Drilling on Federal Lands, N.Y. Times, July 21, 2023 at A12.

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