6.7 Short form citations

Purpose of Short Form Citations

Once you've given the full citation for a source, you don't need to repeat all that information every time you reference it again. Short form citations let you point back to a previously cited source in a compact way, keeping your writing clean and your reader focused on your argument rather than wading through repetitive bibliographic details.

There are three main short form tools: Id., supra, and hereinafter. Each one applies in different situations depending on how recently you cited the source and what type of source it is. Choosing the wrong one is a common and avoidable mistake, so understanding when each applies matters.

Why short forms exist

• They cut down on repetition, saving space and improving the flow of your argument.
• They let readers stay focused on your analysis instead of getting distracted by long citations.
• They make it easier to track which authorities you're relying on throughout a document.
• They also simplify revisions, since you're updating fewer full citations.

Types of Short Form Citations

Id. Citations

Id. is the shortest short form. You use it when you're citing the exact same source as the one in the immediately preceding citation (or footnote). Think of it as saying "same source as the one I just mentioned."

• If you're citing the same page, just write Id. (italicized, with a period).
• If you're citing a different page of the same source, write Id. at [page number].

Example: If footnote 5 cites Smith v. Jones, 500 U.S. 100, 105 (1995), and footnote 6 references page 110 of that same case, footnote 6 would read: Id. at 110.

Supra Citations

Supra is used when you want to reference a source you cited earlier, but not in the immediately preceding citation. It literally means "above," pointing the reader back to the footnote where the full citation appeared.

The format is: [Author's last name], supra note [footnote number], at [pincite].

For example: Epstein, supra note 3, at 47.

One critical restriction: supra cannot be used for cases or statutes in court documents. It's primarily for secondary sources like books, articles, and reports. For cases, you use a different short form (typically a shortened case name with volume and page information).

Hereinafter Citations

Hereinafter lets you assign a nickname to a source with a long or unwieldy title so you don't have to repeat it. You introduce the shortened name in brackets right after the first full citation.

The format looks like this: [full citation] [hereinafter Shortened Name].

For example: U.N. Comm. on the Rights of the Child, General Comment No. 14 on the Right of the Child to Have His or Her Best Interests Taken as a Primary Consideration, U.N. Doc. CRC/C/GC/14 (2013) [hereinafter General Comment No. 14].

After that, every subsequent reference just uses the shortened name. Pick something recognizable that clearly connects back to the original title.

Rules for Short Form Citations

Bluebook Guidelines

The Bluebook is the dominant citation manual in U.S. legal writing. It specifies:

• When Id., supra, and hereinafter are each appropriate
• Which elements get italicized (Id. and supra are always italicized)
• How to handle pincites in short forms
• Source-specific short form formats (cases get different treatment than secondary sources)

The Bluebook is updated periodically, so always check which edition your school or court requires.

ALWD Citation Manual

The ALWD Guide to Legal Citation is an alternative system used at some law schools. It largely tracks the Bluebook but tends to offer clearer explanations and more examples. The formatting differences between the two are usually minor, but you should know which system your professor or jurisdiction expects and stick with it consistently.

Id. Citation Usage

When to Use Id.

Id. works only for immediately consecutive references to the same source. If footnote 12 cites Source A and footnote 13 also cites Source A, footnote 13 can use Id. You can chain multiple Id. citations in a row as long as you keep citing the same source.

The moment you cite a different source, the Id. chain breaks. To reference Source A again after that, you'll need supra or another short form.

Common Exceptions and Pitfalls

• New paragraphs: Many practitioners avoid starting a new paragraph or section with Id. because the reader may have lost track of what "same source" means.
• Multi-author sources: Don't use Id. if you're shifting to a different author within the same collected work.
• Footnotes that might move: If you're still drafting and footnotes could get reordered, Id. references can easily become wrong. Some writers wait until final editing to convert citations to Id.

Supra Citation Format

Setting Up the First Reference

Your first citation to a source must be a full citation with all required bibliographic information. This full citation gets a footnote number that all future supra references will point back to. If the source has a long title, this is also where you'd introduce a hereinafter designation.

Building the Subsequent Reference

A supra citation follows this structure:

1. Start with the author's last name (or shortened title if there's no single author).
2. Add a comma, then supra (italicized).
3. Write "note" followed by the footnote number of the original full citation.
4. If you're pointing to a specific page or section, add ", at [pincite]."

Example: Chemerinsky, supra note 12, at 304.

Remember: no publication date, no publisher, no other full-citation elements. The supra reference tells the reader exactly where to find all of that.

Hereinafter Citation Application

When to Use It

Hereinafter is most useful when:

• A source title is so long that repeating even a shortened version would be cumbersome
• You're citing the same source many times throughout a document
• Multiple works by the same author need to be distinguished quickly

It shows up most often in academic legal writing and lengthy research papers, though it can appear in any legal document.

Format and Placement

1. Write out the complete full citation.
2. Immediately after, add brackets: [hereinafter Shortened Name].
3. In every subsequent reference, use only the shortened name you chose.

The shortened name should be intuitive. A reader who sees it should be able to connect it to the original source without flipping back.

Short Forms for Different Source Types

Cases vs. Statutes

• Cases: The typical short form uses one party name plus the volume, reporter, and pincite. For example, Smith, 500 U.S. at 112. You cannot use supra for cases in court filings.
• Statutes: Short forms usually abbreviate the code name and include the specific section. For example, $\S$ 302(a). Statutes also cannot use supra in court documents.

Secondary Sources vs. Internet Sources

• Secondary sources (law review articles, treatises, books) are the primary candidates for supra and hereinafter. The short form typically includes the author's last name and supra note reference.
• Internet sources can be trickier because URLs change and content gets updated. You may need to provide full citations more frequently for online-only materials. Use paragraph numbers or section headings as pincites when page numbers aren't available.

Common Mistakes in Short Citations

Overusing Id.

This is probably the most frequent error. Watch for these specific problems:

• Using Id. when the immediately preceding citation is actually to a different source
• Using Id. to open a new paragraph, leaving the reader unsure which source you mean
• Chaining so many Id. citations that a reader has to scroll back through dozens of footnotes to find the original source

Incorrect Supra Formatting

• Forgetting to include the original footnote number (the whole point of supra is to direct the reader back to a specific footnote)
• Leaving out a pincite when you're referencing a different page than the original citation
• Using supra for cases in a court brief, which the Bluebook prohibits
• Getting the author's name wrong or using an unclear shortened title

Short Forms in Different Legal Documents

Memos vs. Briefs

Office memos are internal documents written for colleagues who are already familiar with the relevant authorities. Short forms can be used liberally here, and the tone is generally more efficient.

Briefs are submitted to courts, where judges and clerks need to quickly identify and verify your sources. Key authorities often warrant full citations or near-full citations, especially on first reference in each major section. Courts may also have local rules about citation format.

Academic Writing vs. Court Documents

Academic legal writing (law review articles, seminar papers) allows the most flexibility with supra and hereinafter. You'll see these short forms constantly in footnote-heavy scholarship.

Court documents are more conservative. Cases and statutes generally require their own specific short forms rather than supra. Judges want to see the case name and reporter information without having to hunt through earlier footnotes.

Electronic Source Considerations

Pincites for Online Materials

Many online sources don't have fixed page numbers. When that's the case:

• Use paragraph numbers if the source provides them.
• Reference section headings or other stable structural markers.
• For frequently updated content, include a date or timestamp to help the reader locate the version you cited.

Short Forms for Websites

Website short forms need to balance brevity with enough information for the reader to find the source. A shortened title or author name usually works. Avoid relying on URLs as your primary short form since they can break or change. If a web source is unstable, consider citing it in full more often rather than relying on a short form that might lead to a dead link.

Ethical Considerations

Accuracy vs. Convenience

Short forms exist to make writing more efficient, but that efficiency can't come at the cost of accuracy. A misplaced footnote number in a supra citation or a broken Id. chain can send a reader to the wrong source entirely. Always verify your short form citations during final proofreading, especially in documents where footnotes have been added, deleted, or reordered.

Transparency in Citation Practice

Every citation, whether full or short, serves the same purpose: letting your reader find and verify your source. If a short form makes that harder rather than easier, use a fuller citation instead. Proper attribution isn't just a formatting requirement; it's a professional obligation that supports the credibility of your arguments and the integrity of legal writing as a whole.