Build a citation you can explain

The opening problem

A quotation looks exact, yet the writer changed a word, removed a condition, and used a PDF page number instead of the opinion's reporter page. These are distinct defects. The citation must lead to the passage, and the quotation must preserve what the passage means.

What you will learn

Choose pages, paragraphs, sections, and page/line references; format ranges and footnotes; distinguish exact quotation from paraphrase; disclose substitutions, omissions, and emphasis; and format block quotations. Select the permitted alteration method without changing the source's meaning.

Match the pinpoint to the source's structure

A page reference points to a page in the source's stable pagination. A paragraph reference points to a formally numbered paragraph. A section reference points to a provision, including its supplied subsections. A transcript may require both page and line. Choose a coordinate the source actually supplies. Do not invent paragraph numbers by counting paragraphs on a webpage that can reflow.

A full reported-case citation places the pinpoint after the first page, separated by a comma. A short case citation commonly uses at before its page pinpoint. Section and paragraph symbols do not use at. Write § 12 or ¶ 8, not at § 12 or at ¶ 8. Preserve the source's subsection punctuation, such as (a)(2)(B), because changing a capital letter or hyphen may point to another provision.

Use commas for scattered pages and a hyphen for a continuous range in this handbook. A range such as 1240-41 drops repeated leading digits; 199-201 retains the digits needed across the hundred boundary. Use §§ or ¶¶ for multiple sections or paragraphs. Where a source's numbering already contains hyphens, to can express a range more clearly. Avoid vague et seq. when the relevant provisions can be identified precisely.

A footnote pinpoint includes the page and n. immediately followed by its number: 248 n.3. The page identifies where the note appears; the note number identifies the note. Similar source-specific locators may include cmt. for a comment or fig. for a figure. Do not cite a footnote number without confirming that it belongs to the indicated page and version.

The annotated model

Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986) (explaining when a dispute about a material fact is genuine).

The opinion begins at 242. At 248, the majority explains that a material-fact dispute is genuine when the evidence would permit a reasonable jury to return a verdict for the nonmoving party. The inspected passage also distinguishes material disputes from irrelevant ones. The paraphrase addresses this test for a genuine dispute; it does not attempt to state every requirement for summary judgment.

After a full citation has been introduced and the reference is clear, a short citation to that location is Anderson, 477 U.S. at 248. A sequential citation may be Id. at 248 if the immediately preceding citation contains only that source. Chapter 6 explains the limits. The page number remains the same even though the short form changes the arrangement around it.

Quotation and paraphrase demand different checks

A quotation claims to reproduce words. Check its spelling, capitalization, punctuation, emphasis, and context against the inspected source. A paraphrase uses your own words but still must preserve conditions and limitations. Neither method permits turning may into must, some into all, or the nonmoving party into the moving party.

Short quotations of forty-nine words or fewer normally appear within double quotation marks. Periods and commas used to conclude quoted material go inside the closing quotation mark under this baseline. Other punctuation goes inside only when it belongs to the quoted text. A quotation inside a quotation ordinarily uses single quotation marks within the outer double marks. Check the actual nesting before mechanically replacing quotation marks.

For a substitution, enclose the changed letter or word in brackets. To begin a quoted sentence with a lowercase source word that you capitalize, use [T] if the original begins the selected phrase with t. A bracketed clarification such as [the agency] must accurately identify the original referent; it must not smuggle a disputed interpretation into the court's words.

To omit words from the middle of quoted material, use three spaced periods, written . . . within the quotation. The three periods expressing an ellipsis are distinct from a sentence-ending period. Omitting an ending within a sentence may therefore produce three ellipsis periods plus the sentence period. Do not add an initial ellipsis merely because you begin quoting partway into a sentence. Complete sentences omitted after the end of your quotation do not automatically require an ellipsis. Examine the precise boundary rather than applying one punctuation shortcut to every omission.

If you remove a citation or footnote marker from quoted text, this handbook's explicit-disclosure convention uses an accurate omission parenthetical, without an ellipsis solely for that removal. Added emphasis takes (emphasis added); omitted emphasis should be disclosed. Preserve emphasis already in the source without claiming you added it. Retain a material original error with [sic] only when reproducing that error matters; paraphrasing may be clearer than turning an incidental typo into a distraction.

A worked alteration

Fictional training example — not legal authority. The supplied sentence is: “The agency may extend the filing period if the applicant shows good cause.” A writer wants a shorter quotation. “The agency may extend the filing period” reproduces words, but presenting it as an unconditional power can mislead by removing the good-cause condition. The safest repair retains the condition or accurately paraphrases the conditional authority.

Fictional training example — not legal authority. A writer changes may to must and puts [must] in brackets. The brackets reveal a change in text, but they do not make the change substantively legitimate. Brackets should not rewrite the rule. Quote the original or paraphrase accurately. The same principle applies to omitted negations and exceptions.

Block quotations

Set off quotations of fifty or more words as blocks. Under the baseline, use single spacing, left and right indentation, and justified text; omit outer quotation marks. Internal quotation marks remain when present in the quoted passage. Place the following citation at the ordinary left margin rather than inside the indentation. Keep the block's source and pinpoint clear. The reader should be able to identify whether a citation within the quoted block belongs to the source or to your document.

A block may need to continue across a page in a long document. A sensible break preserves readable lines and keeps the citation connected to the ending. Do not make an oversized block unbreakable if that creates a mostly empty preceding page. Check the exported layout, not just the editable source.

Edition difference for readability changes

This book's teaching examples ordinarily show individual changes with brackets, ellipses, and accurate parentheticals. You can then compare each change with the source. That is a teaching preference, subject to the receiving document's instructions.

A document governed by Bluebook 22 B5.3 may instead use its specified citation modified convention for permitted readability changes involving nested quoted material. Its scope is limited. It does not authorize changing a condition, substituting a stronger obligation, or disguising whose words are being quoted. The expressions citation modified and cleaned up should not be treated as interchangeable permission to rewrite a passage. Select the governing convention first, then account for any alteration outside its scope. The source note distinguishes the consulted editions.

Common mistakes and corrections

Replace the viewer's page counter with the appropriate source pagination. Replace at ¶ with ¶. Restore a condition omitted from a misleading quotation. Do not use brackets as permission to change the source's meaning. Do not label a paraphrase a quotation. Do not use cleaned up or citation modified as a substitute for checking each word and the cited source's context.

Reference summary

Use the source's actual coordinates. Separate identification from location. Verify quotations against the source, then assess the effect of every change. Use blocks at fifty words under the taught baseline. Treat readability modifications as bounded conventions subject to the receiving document's requirements.

Worked editing session: maintain an alteration record

Fictional training example — not legal authority. The source says: “The board may reopen an application after thirty days only if the applicant presents newly discovered evidence.” The draft quotes: “The board [must] reopen an application . . . if the applicant presents evidence.”

Compare the changed units before deciding how to mark them:

Each change has a substantive cost. Brackets reveal the first substitution, and the ellipsis reveals an omission, but neither device makes the new rule accurate. Restore the material words or paraphrase: “The board has conditional authority to reopen after thirty days when the applicant presents newly discovered evidence.” The passage supplies no publication metadata; this workshop asks you to edit the text, not fabricate a full citation.

Contrast those changes with a referent clarification. If the preceding sentence clearly identifies the board, changing a quoted it to [the board] can help the reader recover that referent without changing the rule. A capitalization change can serve the same limited purpose. State what each alteration accomplishes. If your explanation is “it makes the source say what my argument needs,” restore the original.

Now check the locator against the words retained. If a quotation spans two source pages, and the second contains the decisive limitation, preserve both locations in the pinpoint. After turning the passage into a block, compare the finished text again: removing the outer quotation marks must not remove a quotation within the source, its limiting final sentence, or the connection to the following citation.

Locate the boundaries of an omission

Fictional training example — not legal authority. The supplied source reads: “The clerk received the signed request on Monday. The clerk entered it in the register on Tuesday. The board considered the request on Friday.” Three accurate excerpts perform different tasks. “The clerk received the signed request on Monday” quotes a complete proposition as a phrase inside your sentence. “The clerk received the signed request . . . .” omits the end of that quoted sentence, preserving a sentence period in addition to the ellipsis. “The clerk received the signed request on Monday. . . . The board considered the request on Friday.” preserves two complete sentences while indicating the omitted intervening sentence. Check the applicable quotation convention and the meaning of each retained statement; omitting the registration event would be misleading if your sentence depended on when registration occurred.

Fictional training example — not legal authority. The source says “The clerk received the requests.” Changing its plural to a singular for legitimate grammatical integration produces “The clerk received the request[].” under the omitted-letter convention used here. This mechanical example does not authorize turning a proposition about several requests into a proposition about one identified request unless the surrounding source supports that narrowing. A faithful paraphrase often reads more naturally.

For a quotation containing an existing bracketed alteration, distinguish your work from the source's. An appropriate (alteration in original) parenthetical says that the alteration came from the quoted source. Do not label your own new clarification that way. Likewise, an (emphasis added) parenthetical should correspond to emphasis you introduced. Keep a marked source excerpt so another editing pass can distinguish original and added emphasis without guessing.

Apply the receiving quotation instruction

Removing a source's citation is different from removing its substantive words. A citation tells the reader where the source obtained support; a condition such as only upon a showing of good cause defines what the source says. When a receiving instruction permits you to omit embedded citations, that permission does not automatically extend to qualifications in the surrounding prose.

Use three decisions. First, mark exactly what will disappear: an authority reference, a footnote marker, or substantive language. Second, preserve the material meaning of every retained sentence, including any qualification surrounding the removed item. Third, supply the disclosure required by the receiving instruction. Under this book's explicit-disclosure teaching convention, removing only a citation takes an accurate omission parenthetical without an ellipsis solely for that removal. Exercise 4.8 supplies the controlling instruction so you can apply it without guessing a court's preference.

Source laboratory: a quotation that cannot become a verdict

Tolan v. Cotton supplies a practical context test. The Supreme Court's per curiam opinion faulted the appellate court for resolving disputed evidence against the party opposing summary judgment. It identified disputes about lighting, demeanor, words, and position. 572 U.S. 650, 657-60 (2014) (per curiam). At page 660, however, the Court expressly declined to decide whether the officer's conduct violated clearly established law. It vacated the judgment and remanded for further proceedings.

A paragraph saying, “The Supreme Court found that the officer violated clearly established law,” would therefore misstate the inspected decision. Quoting the criticism of the appellate court without the qualification would not cure it. A supported account is: “The Court required the appellate court to credit the nonmovant's evidence and draw reasonable inferences in his favor, while leaving the clearly-established-law question unresolved. Tolan v. Cotton, 572 U.S. 650, 660 (2014) (per curiam).” The sentence describes the procedural correction and its limit together.

Notice what the pinpoint does. Page 660 supplies both the correction and the reservation. A broader discussion of which factual disputes were overlooked needs pages 657-60. A quotation taken from page 658 should not be assigned page 660 merely because 660 contains a convenient conclusion. Build a two-column note: words used, location inspected. Add a third column for any qualification needed to explain those words. Only then choose one pinpoint, several pinpoints, or a range.

This is a reusable quotation test: if the next sentence changes what your excerpt appears to establish, your reader needs that qualification in the quotation, your paraphrase, or the surrounding analysis. Preserving every letter in a short excerpt is insufficient when the excerpt is made to answer a question the Court expressly reserved.

Takeaway

Pinpoints locate the evidence. Quotation treatment describes what you did to it. Both must remain accurate after every edit.

Chapter source note

Indigo 2.0 R5, R8, R9, R10, R11.7. Real authority EX-003: Anderson, majority at 248. Licensed comparison: Bluebook 22 B5.3, read October 7, 2026. Its text is not reproduced as adaptation material.

Additional source: Tolan v. Cotton, 572 U.S. 650, 651-60 (2014) (per curiam), full per curiam opinion and its notes inspected, including the reservation at 660; RA-EX-003.

Convention notes: Indigo R8.2.1 supplies the omitted-letter pattern. R8.2.4 and R8.3.6 provide omission-disclosure directions that conflict with R8.2.6; this book chooses explicit disclosure for teaching examples rather than treating the source as unanimous. Exercise 4.8 independently supplies its receiving instruction. Indigo describes cleaned up as evolving practice; the consulted Bluebook 22 B5.3 provides a bounded citation-modified convention. Neither is represented as a universal receiving-court requirement.