The Bluebook: A Uniform System of Citation is a style guide that prescribes the most widely used legal citation system in the United States. It is taught and used at a majority of law schools in the United States and is also used in a majority of federal courts. Legal publishers also use several "house" citation styles in their works.
The Bluebook is compiled by the Harvard Law Review, Columbia Law Review, Yale Law Journal, and University of Pennsylvania Law Review. Currently, it is in its 22nd edition (published May 2025). Its name was first used for the 6th edition (1939). Opinions have differed regarding its origins at Yale and Harvard Law Schools, with the latter long claiming credit.
The Supreme Court uses its own unique citation style in its opinions, even though most of the justices and their law clerks obtained their legal education at law schools that use The Bluebook. Furthermore, many state courts have their own citation rules that take precedence over the guide for documents filed with those courts. Some of the local rules are simple modifications to The Bluebook system. Delaware's Supreme Court has promulgated rules of citation for unreported cases markedly different from its standards, and custom in that state as to the citation format of the Delaware Uniform Citation codeRohrbacher, Blake "Delaware Uniform Citation" 2008. Retrieved February 21, 2024. also differs from it.Rule 14(g), Rules of the Supreme Court of the State of Delaware. In other states, the local rules differ from The Bluebook in that they use their own style guides. Attorneys in those states must be able to switch seamlessly between citation styles depending upon whether their work product is intended for a federal or state court. California has allowed citations in Bluebook as well as the state's own style manual,Cal. Rule of Court 1.200 but many practitioners and courts continue recommending the California Style Manual.
An online-subscription version of The Bluebook was launched in 2008.The Bluebook Legal Citation Guide Now Available Online, (February 22, 2008) (archived from original October 9, 2013). A mobile version was launched in 2012 within the Rulebook app, which enables access for legal professionals to federal or state court rules, codes, and style manuals on iPads and other mobile devices. 142 (Ellyssa Kroski ed. 2013); Gabriella Khorasanee, There's An App For That: Top 10 Apps for Law Students, , (Aug. 23, 2013) (archived from original Dec. 6, 2013).
Elements
The 22nd edition of The Bluebook governs the style and formatting of various references and elements of a legal publication, including:
Structure and use of citations Typefaces for law reviews Subdivisions Short citation forms (for use when a document makes multiple references to the same case)Georgetown Law Library, Bluebook Guide: Short Citation Forms, accessed on 28 December 2024 Quotations Abbreviations, numerals, and symbols Italicization for style and in unique circumstances Capitalization Titles of judges, officials, and terms of court Cases Constitutions Statutes Legislative materials Administrative and executive materials Books, reports, and other nonperiodic materials Periodical materials Unpublished and forthcoming sources Electronic media and other nonprint resources Services Foreign materials International materials
History While legal citation manuals go as far back as Modus Legendi Abbreviaturas in Utroque Iure, published around 1475, there were very few examples prior to the 20th century; law professor Byron D. Cooper mentions only a few short articles: "Rules for Citation" (The American Law Review, 1896) and "Methods of Citing Statute Law" (Ruppenthal, Law Library Journal, 1919). The Uniform System of Citations thus became a "pioneer" manual.
According to Harvard, the origin of The Bluebook was a pamphlet for proper citation forms for articles in the Harvard Law Review written by its editor, Erwin Griswold.Christine Hurt, The Bluebook at Eighteen: Reflecting and Ratifying Current Trends in Legal Scholarship, 82 49, 51–52 (2007). However, according to a 2016 study by two Yale librarians,Fred R. Shapiro & Julie Graves Krishnaswami, The Secret History of the Bluebook, 100 1563 (2016). Harvard's claim is incorrect. They trace the origin of The Bluebook to a 1920 publication by Karl Llewellyn at Yale on how to write law journal materials for the Yale Law Journal. (1920). This booklet had a blue cover, which Shapiro and Krishnaswami point out is "appropriate for its University," whose official color is blue. The authors point out that some of the material in the 1926 first edition of The Bluebook (as well as that in a 1922 Harvard precursor to it published as Instructions for Editorial Work) duplicate material in the 1920 Llewellen booklet and its 1921 successor, a blue pamphlet that the Yale Law Journal published as Abbreviations and Form of Citation.According to Shapiro and Krishnaswami: Bluebook 1 (1926) has approximately 30 sentences in common with Yale Law Journal ’s Abbreviations and Form of Citation (1921), as well as many of the sample citations, all of the proofreading signs, and virtually all of the items in the long list of abbreviations. They both begin with the same sentence: “This pamphlet does not pretend to include a complete list of abbreviations or all the necessary data as to form.” The subtitle of the Bluebook is “Abbreviations and Form of Citation.” The Jones v. Smith Connecticut citation that is the basic case citation example used by the Yale precursors back to Llewellyn-Field is the basic case example used in Bluebook 1. The Haines Yale Law Journal citation that is the basic periodical citation example used by the Yale precursors back to Llewellyn-Field is the basic periodical example used in Bluebook 1. Most of the section on treatises is identical between 1921 and 1926.
For several years before the first edition of The Bluebook appeared, Yale, Columbia, and several other law journals "worked out a tentative citation plan", but Harvard initially opposed it "because of skepticism as to the results to be attained and in part because of a desire not to deviate from our forms especially at the solicitation of other Reviews". Eventually, Harvard reversed course and joined the coalition by 1926. According to Judge Henry J. Friendly, "Attorney General [Herbert] Brownell ... and I and two others [from Columbia and Pennsylvania] were the authors of the first edition of the Bluebook."David M. Dorsen, 71 (2012). Friendly has also sometimes been considered the creator of The Bluebook.
The cover of the 1926 A Uniform System of Citation was green. The color was "brown from the second (1928) edition through the fifth (1936) edition. It was only with the sixth (1939) edition that it became blue."Shapiro and Krishnaswami. In 1939, the cover of the book was changed from brown to a "more patriotic blue", allegedly to avoid comparison with a color associated with Nazi Germany.A. Darby Dickerson, An Un-Uniform System of Citation: Surviving with the New Bluebook, 26 53, 58–60 (1996). According to Shapiro and Krishnaswami, however, "The abandonment of brown is often attributed to the association of that color with Nazi Germany in the 1930s, but that idea appears to trace to a joke by Alan Strasser," in Technical Due Process: ?, 12 507, 508 (1977). Strasser states, referring to the eleventh edition's change of cover color to white with a blue border promising a "new life," that "the 1939 Blue Book had electrified the nation by parading patriotic blue covers instead of the Germanic brown ones that had disgraced the 1936 edition." Id. (footnote omitted). The eleventh edition, published in 1967, was actually white with a blue border.All the Fun Facts about the Bluebook. The cover color returned to blue in the twelfth edition of 1976.Strasser, at 508. Strasser states that the first printing was a "timid" blue-gray but later printings were a "more self-assured" navy blue. Id. n.9.
The full text of the first (1926) through the fifteenth (1991) editions is available on the official website.Introduction, , (2010), (archived from the original June 24, 2013).
The Bluebook uses two different styles. Practitioners use the first in preparing court documents and memoranda, while the second is used primarily in academic settings, such as law reviews and journals., 9 (2001). The latter uses specific formatting to identify types of references, such as the use of small caps for books, newspapers, and law reviews., at 9–10. A rule of thumb used by many is to see if the formatting can be reproduced on a typewriter—if so, practitioners use it, if it requires typesetting, it is used for academic articles., at 10.
By 2011, The Bluebook was "the main guide and source of authority" on legal references for the past 90 years., 468 (4th ed. 2011). It is recognized as the "gold standard" for legal references in the United States, even though it was originally designed only to help teach law students how to cite cases and other legal material., at 1–2. Although other citation systems exist, they have limited acceptance, and in general, The Bluebook is followed in the legal citation as the most widely accepted citation style,, at 468; , at 2; Kroski, at 263. called the "Bible", the "final arbiter", even the legal citation "Kama Sutra". Some states have adopted The Bluebook in full, while others have partially adopted The Bluebook., at 468–69. States such as Texas have supplements, such as The Greenbook, that merely address citation issues unique to Texas and otherwise follow The Bluebook., 16 (2003); iv (12th ed. 2010).
Variations
Federal The Solicitor General issues a style guide that is designed to supplement The Bluebook. 1 (Jack Metzler ed. 2007). This guide focuses on citation for practitioners, such as restraining law reviews to two typefaces: normal and italics.Metzler, at 14. Other changes are similarly minor, such as moving supra from before the page referenced to after the page number.Metzler, at 20. The guide does state that unless explicitly specified otherwise, The Bluebook rule takes precedence in the event of conflict.Metzler, at 1.
State California used to require use of the California Style Manual., 1 (4th ed. 2000). In 2008, the California Supreme Court issued a rule giving an option of using either the California Style Manual or The Bluebook.2013 Calif. R. of Ct. 1.200; 30 (Mary Miles Prince ed., 19th ed. 2010). The two styles are significantly different in citing cases, in use of ibid. or id. (for ), and in citing books and journals.Legal Research and Writing Manual, (2013). Michigan uses a separate official citation system issued as an administrative order of the Michigan Supreme Court.Elan S. Nichols, Checklists for Drafting, Formatting, and Submitting Litigation and Other Documents: Instructive Material for Law Students Practicing in Law School Clinics, and Reminders for the Practicing Attorney and Her Staff, 15 57, 58 (2013). The primary difference is that the Michigan system "omits all periods in citations, uses italics somewhat differently, and does not use 'small caps.'"Nichols, at 58 n.3. As noted above, Texas merely supplements The Bluebook with items that are unique to Texas courts, such as citing cases when Texas was an independent republic,, at 101. petition and writ history,, at 20–26. and Attorney General Opinions., at 76–78.
Reception
Criticism of Bluebooks prolixity
At over 500 pages for the 19th edition, The Bluebook is significantly more complicated than the citation systems used by most other fields. Legal scholars have called for its replacement with a simpler system.Richard A. Posner, The Bluebook Blues, 120 850–861 (2011). The University of Chicago uses the simplified Maroonbook,80 1 (Bradley G. Hubbard, Taylor A.R. Meehan, & Kenneth A. Young eds. 2013). and even simpler systems are in use by other parties.