Parallel Citations | Federal Codes | States Codes

Say you have been asked to read Brown v. Board of Education, 347 U.S. 483.

This is an example of a legal citation to a case. Citations are abbreviated references to legal sources, such as court reporters, statutory compilations, and law reviews. Citations generally follow this standard format:

Brown v. Board of Education, 347 U.S. 483

Party Names	347	U.S.	483
Brown v. Board of Education	Volume number	Abbreviated Court Reporter Title	Page or Section Number

The difficulty with citations lies in deciphering the abbreviations of the source title. The Bluebook lists the abbreviations used for each court reporter, statutory compilation and law review. In the above example, U.S. stands for United States Reports, a publication of United States Supreme Court decisions.

So now you know that Brown v. Board of Education is located in volume 347, page 483 of the United States Reports.

However, opinions of certain courts are often published in more than one court reporter. Citations to the same case in different reporters are called parallel citations. For example, opinions of the US Supreme Court may be found in three different court reporters:

• United States Reports (U.S.), published by the US government, this is the official reporter,
• Supreme Court Reporter (S.Ct.), an unofficial reporter published by West Publishing and
• United States Supreme Court Reports, Lawyer's Edition (L.Ed.), another unofficial reporter published by Lexis Publishing.

So your citation might look like this:

Brown v. Board of Education, 347 U.S. 483, 74 S. Ct. 686, 98 L. Ed. 873

This is an example of a legal citation to a section of the United States Code (USC). The USC is the text of the statutory law arranged by subject. Statutes are first broken down into titles. So for example statutes pertaining to civil rights fall within Title 49; those pertaining to labor fall under Title 26. Statutes are further broken down into chapter and section numbers.

For 42 USC 1981, the first number in the citation refers to the title of the code and the last number refers to the section number of the code:

42 USC 1981

42	USC	1981
Title Number	Abbreviated Name of the Code Compilation	Section Number

So to find that code section, you would go to the United States Code, locate the volume that has Title 42 on the spine and find section 1981 within that volume.

States may or may not differ from the federal model. For example, Ohio follows the federal model but California differs slightly. Instead of title numbers, California code citations refer to title names.

A citation to the California Unruh Civil Rights Act law looks like this:

Cal Civ Code § 51 (Deering 2001)

Remember: if you do not recognize a reporter or statutory compilation abbreviation, check the Bluebook.

The Bluebook rule for citing a code section is 12.3.  Pay particular attention to the year of the code you are citing.  Only if the statute had been amended since the principal volume was published would you then also cite to a supplement or a more recent electronic compilation.  If you are citing to the supplement you would reflect that in the citation.  If the the reader would have to compile both the supplement, or pocket part, together with the principal volumbe then you would cite both in parentheses.

Examples:

Cal. Pub. Res. Code § 21091 (West Supp. 1990)

Cal. Lab. Code § 5304 (Deering 1976)

Cal. Gov't Code § 825 (West Supp. 1998)

Cal. Veh. Code § 11509 (West 1987 & Supp. 1991)

Page updated: March 30, 2008