Citation form: The Tyranny of the Inconsequential

I wrote about this before, in 2006, but here I go again.

“Mastering the arcana of citation forms . . . is not a productive use of judges’ or law clerks’ time. The purpose of citations is to assist researchers in identifying and finding the sources; a form of citation that will serve that end is sufficient. In addition, the form of citation should be consistent to avoid the appearance of lack of craftsmanship and care.”

Judicial Writing Manual 24 (Fed. Jud. Ctr. 1991).

I agree with this quotation entirely. But it doesn’t reflect reality. Lawyers, especially judicial clerks, will judge you by your citation form, as inconsequential as it may be.

I call it the tyranny of the inconsequential.

Before I offer 3 exhibits to support my point, let me be clear: I’m talking only about citation form, not citation substance. For example, in a case citation, if the case name is wrong, if the page number is wrong, if the year is wrong—that’s a problem. Those are substantive mistakes. I’m talking about form.

For example:

  • Whether you leave a space between F. and Supp.
  • Whether you use “and” or “&”
  • Whether you spell out “Gender” or abbreviate it “Gend.”
  • Whether you carry out 3 digits (343-344) or 2 digits (343-44)

These matters of form are not substantively relevant, I say. They shouldn’t matter, but they do.


  • Because citation form is a wrong-or-right matter, without subjectivity, it’s an easy proxy for assessing the caliber of a piece of writing.
  • Because you create citation forms by consulting an authority (a citation manual) and applying rules, it’s sort of like legal analysis.
  • Because most lawyers consider themselves nitpickers and strong writers, the weight given to citation-form errors is exaggerated.

Exhibit A: A senior attorney threatens to withhold an offer from a summer associate because her citation form is poor. In reality she is simply using ALWD Manual citation form and the “mistakes” are just different abbreviations, like Assn. vs. Ass’n.

Exhibit B: A students reports that “being on law review improved my writing” but when asked to specify says, “because it helped me master citation form.”

Exhibit C: A judge says, “if the writer made a mistake in citation form, then the writer probably made other, substantive mistakes.”

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