Mastering String Cites in Legal Writing: Rules, Examples & Best Practices

String cites, an essential component of legal writing, form the backbone of strong legal arguments and sound legal research. For example, a string citation, taken from The Bluebook might appear as:

States have required criminal defenses to prove affirmative defenses. See, e.g., Quillen v. State, 110 A.2d 445, 449 (Del. 1955); State v. Skinner, 104 P. 223, 224 (Nev. 1909). See generally Wayne R. LaFave & Austin W. Scott, Jr., Handbook on Criminal Law § 8.1, at 704-06 (2d ed. 1986) (discussing the origin of embezzlement and false pretense.)

This article delves into the intricacies of string citations, offering comprehensive guidelines, rules, and illustrative examples to enhance your legal writing. Whether you are a novice or seasoned attorney, mastering string cites is crucial for citing case law and secondary sources accurately. Proper citation not only bolsters the credibility of your argument but also ensures adherence to the strict standards of legal documentation.

This article covers the following key areas:

• Understanding String Cites in Legal Writing
• The Importance of String Cites in Legal Arguments
• Guidelines for Using String Cites Effectively
• Common Mistakes to Avoid in Legal Citations
• Examples of Properly Formatted String Citations

Let’s delve into the essential aspects of string citations in legal writing and explore how to use them effectively to support your legal arguments.

Understanding String Cites in Legal Writing

String citations, commonly referred to as string cites, are a fundamental aspect of legal writing. They involve listing multiple citations in a single sentence or paragraph to support a legal argument or proposition. This practice allows legal writers to demonstrate that a particular point of law is well-supported by various authorities.

In legal writing, string cites typically follow a statement and are included within a single parenthetical. They serve to bolster the credibility of the legal argument by showing that multiple sources with similar conclusions exist. String cites can include primary and secondary authority sources, such as case law, statutes, regulations, and legal commentaries.

When constructing string cites, it is crucial to adhere to proper legal citation formats as set forth in citation guides like The Bluebook or the ALWD Guide to Legal Citation. These citation manuals provide detailed rules on the order and format of citations, ensuring consistency and clarity in legal documents.

String cites serve several purposes in legal writing:

• Reinforce Authority: By providing numerous sources, string cites underscore the robustness of the legal argument.
• Showcase Comprehensive Research: Including a variety of sources demonstrates thorough legal research and an in-depth understanding of the legal issue.
• Illustrate Uniformity in Jurisprudence: String cites highlight uniform legal principles across multiple jurisdictions, indicating wide acceptance of the argument.

Correct usage of string cites involves placing the most persuasive or authoritative sources first, followed by less critical but still supportive citations. Moreover, each source should be relevant and directly support the legal proposition presented.

Overall, mastering string citations is essential for any proficient legal writer. When done correctly, string cites enhance the persuasiveness and credibility of legal arguments, providing a solid foundation for legal analysis and advocacy. In the subsequent sections, we will delve into the importance of string cites, guidelines for their effective use, common mistakes to avoid, and practical examples to enhance your legal writing skills.

The Importance of String Cites in Legal Arguments

String cites play a critical role in legal arguments, providing substantial benefits that can significantly enhance the persuasiveness and credibility of legal writing. By compiling multiple authoritative sources, string cites demonstrate the depth and breadth of research, which is vital for convincing judges, opposing counsel, or any legal reader of the soundness of an argument.

Below, we outline several key reasons why string citations are important in legal arguments:

• Strengthening Authority: String cites bolster the authority of a legal argument by showcasing that multiple sources support the same legal principle. By citing a range of cases, statutes, and secondary sources, a legal writer can show that a particular point is well-accepted, thereby strengthening the argument’s foundation.
• Demonstrating Comprehensive Research: Utilization of string citations reflects thorough legal research. When legal writers include a variety of sources, they reveal they have carefully and comprehensively reviewed the legal landscape surrounding the issue in question. This not only adds to the persuasiveness of the argument but also increases the writer’s credibility.
• Establishing Precedent Consistency: String cites indicate that a rule or principle is consistently applied across different cases and jurisdictions. This consistency is crucial in persuading a court to adopt a similar approach or ruling as it follows the established legal precedent.
• Reducing the Risk of Rebuttals: By preemptively addressing potential counterarguments through multiple citations, legal writers can reduce the likelihood of their arguments being easily rebutted. Strong, multi-sourced string cites present a more formidable and well-rounded argument.
• Enhancing Persuasive Writing: String citations can make legal writing more persuasive by showing that the argument aligns with a broad consensus within legal authorities. This approach can be particularly effective in appellate briefs where the goal is to show that lower court rulings conform to established legal principles observed in other similar cases.

Consider an example where a legal writer is arguing that a specific statutory provision should be interpreted in a certain way. Including string cites that reference multiple appellate court decisions, treatises, and law review articles all supporting this interpretation would solidify the argument. (Please note that the bulk of the cases and authorities set forth below are fictional, and are simply provided for citation purposes.) For instance:

One should interpret statutory language to restrict the specified activity only in public spaces, as supported by numerous decisions: Doe v. State, 123 F.3d 456 (9th Cir. 2020); Smith v. Jones, 789 F.2d 321 (6th Cir. 2018); and renowned treatises like Restatement (Third) of Torts § 46 (2010); see also J. Legal, Interpretation of Statutes, 45 Harv. L. Rev. 789, 799 (2015).

Such string citations compel the reader to acknowledge that the legal proposition is supported widely, thus validating the argument more convincingly.

In conclusion, string citations are indispensable in legal writing. Their meticulous and strategic use reflects diligence, enhances persuasiveness, and strengthens legal arguments. Following this understanding, we will explore guidelines for using string cites effectively in the next section.

Guidelines for Using String Cites Effectively

String cites are a powerful tool in legal writing, but their effectiveness depends on how they are utilized. Proper use can greatly enhance the persuasive power of a legal argument, while poor use can clutter the writing and confuse the reader. Below are some guidelines to ensure that string citations are used effectively in legal documents.

1. Follow Citation Guides Precisely

Adherence to established citation guides such as The Bluebook or the ALWD Guide to Legal Citation is essential. These guides provide comprehensive rules on the correct order and format for citations. Proper formatting ensures clarity and consistency, allowing the reader to follow the sources and strengthening the credibility of the legal argument.

2. Prioritize Relevance and Authority

Not all sources are equal in terms of relevance and authority. When constructing string cites, it is crucial to prioritize more authoritative and relevant sources. For instance, Supreme Court decisions or landmark cases should be cited before lower court rulings or secondary sources. This hierarchical approach lends more weight to the legal argument.

3. Use a Logical and Methodical Order

Organize string citations in a logical order that makes the argument easy to follow. Typically, you should list sources from the most authoritative to the least, or from the most recent to the earliest. Grouping similar types of sources together (e.g., cases before statutes) can also help maintain logical flow and coherence.

4. Avoid Overloading with Too Many Sources

While it is tempting to include as many citations as possible to demonstrate thorough research, overloading a legal document with too many sources can be counterproductive. Aim for a few strong, directly relevant citations rather than an exhaustive list that may overwhelm the reader. Clarity and precision are key.

5. Ensure Each Source Adds Value

Every source in a string citation should add unique value to the argument. Avoid redundant citations that reiterate the same point without offering additional insight or authority. Each citation should contribute a distinct aspect or perspective that strengthens the overall argument.

6. Integrate String Cites Smoothly

String citations should be integrated seamlessly into the narrative of the legal document. They should support the argument without disrupting the flow of the text. Use transitional phrases to introduce the string cites, such as “see also,” “accord,” or “cf.” This approach ensures a smooth and coherent presentation.

7. Use Parentheticals for Clarification

Parentheticals can provide essential context and clarification for each cited source. A brief parenthetical explanation can highlight the relevance of the source or draw attention to a specific point within a cited case. However, keep parentheticals concise to avoid cluttering the citation.

For example:

Various courts have consistently supported this statutory interpretation (see Doe v. State, 123 F.3d 456, 460 [9th Cir. 2020] [holding that statutory language should be construed narrowly]; Smith v. Jones, 789 F.2d 321, 325 [6th Cir. 2018] [emphasizing the importance of legislative intent]).

8. Consistency is Key

Consistency in citation style and format throughout the document is crucial. This includes uniform use of abbreviated citations, punctuation, and phrases. Consistent string citation practices enhance readability and professionalism, ensuring the document meets the exacting standards of legal writing.

By following these guidelines, legal writers can use string citations effectively to strengthen their arguments, demonstrate comprehensive research, and enhance their persuasive authority. In the following sections, we will explore common mistakes to avoid in legal citations and provide examples of properly formatted string citations.

Common Mistakes to Avoid in Legal Citations

While using string cites can greatly enhance the credibility and persuasive power of legal documents, there are common mistakes that many writers make. Being aware of these pitfalls can help legal writers produce more effective and professional work. Below are some of the most frequent errors to avoid when constructing and using string citations.

1. Overloading the Sentence with Too Many Citations

One common mistake is including an excessive number of citations in a single sentence or parenthetical. While it might seem impressive to list ten or more sources for a single point, this approach can overwhelm the reader and obscure the main argument. Aim for a balance by selecting the most authoritative and relevant sources.

Example of an overloaded sentence:

Several cases have widely endorsed this statutory interpretation: Doe v. State, 123 F.3d 456 (9th Cir. 2020); Smith v. Jones, 789 F.2d 321 (6th Cir. 2018); Brown v. Williams, 555 F. Supp. 2d 1234 (E.D. Wis. 2017); Johnson v. Black, 432 F.3d 654 (7th Cir. 2019); Miller v. Anderson, 657 F.3d 789 (5th Cir. 2016), among others.

2. Using Irrelevant or Weak Sources

Including citations that are not directly relevant or authoritative detracts from the strength of your argument. Ensure that each citation specifically supports the legal point you are making. Secondary sources or lower-court decisions that do not add substantial value should be omitted.

Example of irrelevant citations:

See Smith v. Jones, 789 F.2d 321 (6th Cir. 2018) (discussing unrelated statutory interpretation); Green v. Blue, 234 F. Supp. 3d 456 (D. Md. 2015) (addressing wholly different legal issue).

3. Using Inconsistent Formatting

Inconsistencies in citation format can make a document appear unprofessional and difficult to read. Adhere to a single citation guide, such as The Bluebook, and ensure that all citations are formatted consistently. This includes the use of italics, abbreviations, and punctuation.

Example of inconsistent formatting:

See Smith v. Jones, 789 F.2d 321 (6th Cir. 2018); See also Green v. Blue, 234 F. Supp. 3d 456 [D.MD. 2015], accord Johnson v. Black, 432 F.3d 654 (7th Cir 2019).

4. Failing to Provide Parenthetical Explanations

Parentheticals provide context that helps the reader understand the significance of each citation. Failing to include them, or including vague explanations, can confuse the reader. Ensure each parenthetical is specific and concise.

Example of lacking parentheticals:

See Smith v. Jones, 789 F.2d 321 (6th Cir. 2018); Green v. Blue, 234 F. Supp. 3d 456 (D. Md. 2015); Johnson v. Black, 432 F.3d 654 (7th Cir. 2019).

Improved with parentheticals:

See Smith v. Jones, 789 F.2d 321, 326 (6th Cir. 2018) (interpreting statutory language narrowly); Green v. Blue, 234 F. Supp. 3d 456, 460 (D. Md. 2015) (emphasizing legislative intent); Johnson v. Black, 432 F.3d 654, 659 (7th Cir. 2019) (applying a similar statutory interpretation).

5. Ignoring the Hierarchy of Authorities

Not all legal authorities carry the same weight. Supreme Court decisions and higher appellate court cases should be prioritized over lower court and unreported decisions. Misunderstanding this hierarchy can weaken the argument.

Example of an incorrect hierarchy:

See Doe v. State, 123 F.3d 456 (9th Cir. 2020); Miller v. Anderson, 657 F.3d 789 (5th Cir. 2016); Brown v. Williams, 555 F. Supp. 2d 1234 (E.D. Wis. 2017); Smith v. Jones, 789 F.2d 321 (6th Cir. 2018); Johnson v. Black, 432 F.3d 654 (7th Cir. 2019).

Improved hierarchy:

See Miller v. Anderson, 657 F.3d 789 (5th Cir. 2016); Smith v. Jones, 789 F.2d 321 (6th Cir. 2018); Johnson v. Black, 432 F.3d 654 (7th Cir. 2019); Doe v. State,123 F.3d 456 (9th Cir. 2020); Brown v. Williams, 555 F. Supp. 2d 1234 (E.D. Wis. 2017).

6. Misplacing Punctuation and Italics

Error in punctuation and use of italics can lead to confusion and make your citations look sloppy. Ensure that case names are italicized or underlined, commas and periods are placed inside quotation marks, and semicolons properly separate citations within a string cite.

Example of misplaced punctuation and italics:

See Smith v. Jones, 789 F.2d 321 (6th Cir. 2018), Green v. Blue, 234 F. Supp. 3d 456 (D. Md. 2015); Johnson v. Black, 432 F.3d 654 (7th Cir. 2019).

Correct formatting:

See Smith v. Jones, 789 F.2d 321 (6th Cir. 2018); Green v. Blue, 234 F. Supp. 3d 456 (D. Md. 2015); Johnson v. Black, 432 F.3d 654 (7th Cir. 2019).

Avoiding these common mistakes can significantly improve the clarity, readability, and persuasiveness of your legal documents. In the next section, we will provide specific examples of properly formatted string citations.

Examples of Properly Formatted String Citations

Understanding how to format string citations correctly is crucial for maintaining the credibility and professionalism of legal documents. Below are several examples that illustrate the proper use of string cites in legal writing, adhering to guidelines from The Bluebook and other citation standards.

Example 1: Case Law String Citations

When referencing multiple cases to support a legal proposition, organizing them by jurisdiction or authority level is important. Here is an example showing proper formatting:

Courts have consistently held that statutory interpretation must adhere to the plain meaning rule. United States v. Ron Pair Enters., Inc., 489 U.S. 235, 241 (1989); Chevron U.S.A., Inc. v. Natural Res. Def. Council, Inc.*, 467 U.S. 837, 842 (1984); Smith v. Jones, 789 F.2d 321, 325 (6th Cir. 2018).

In this example, the drafter would list a Supreme Court case before a lower appellate court case, showcasing the hierarchy of authority. (*Please note that the United States Supreme Court, in Loper Bright Enterprises v. Raimondo,  ___ U.S. ___ (2024), overturned the doctrine of Chevron deference, no longer permitting governmental entities to defer to administrative agency interpretation of ambiguous federal statutes, and instead finding that the judiciary is the sole authority to “say what the law is.”  The use of Chevron here is simply to illustrate how to provide string citations, when Chevron was still good law.)

Example 2: Combining Cases and Secondary Sources

String cites may combine case law and secondary sources to provide a well-rounded argument. Properly formatting these different types of citations is key:

The principle of judicial review is well-established in constitutional law. See Marbury v. Madison, 5 U.S. 137, 177 (1803); Chevron U.S.A., Inc. v. Natural Res. Def. Council, Inc., 467 U.S. 837, 842 (1984); Laurence H. Tribe, 1 American Constitutional Law 517 (3d ed. 2000).

Here, the Supreme Court decisions are listed first, followed by a treatise for a comprehensive understanding of the principle.

Example 3: Using Parentheticals for Clarity

Parentheticals provide context for each citation, enhancing the reader’s understanding of the relevance of each source:

Several courts have interpreted similar statutory provisions narrowly. See Doe v. State, 123 F.3d 456, 460 (9th Cir. 2020) (holding that statutory language should be construed narrowly); Smith v. Jones, 789 F.2d 321, 326 (6th Cir. 2018) (emphasizing legislative intent); Johnson v. Black, 432 F.3d 654, 659 (7th Cir. 2019) (applying a narrow statutory interpretation).

Including parentheticals makes it clear why each case is relevant to the argument presented.

Example 4: Sequential Statutory Citations

When citing multiple statutes, it is essential to format them in a manner that is easy to follow:

The defendant’s actions violated several statutory provisions. See 18 U.S.C. § 2113(a) (defining bank robbery); 18 U.S.C. § 1951 (prohibiting interference with commerce by threats or violence); 18 U.S.C. § 924(c) (related to the use of firearms during and in relation to a crime of violence).

This example lists federal statutes in numerical order, with each statute given a brief parenthetical explanation.

Example 5: Combining Statutes, Cases, and Administrative Regulations

String citations may also combine various types of legal sources, such as statutes, cases, and administrative regulations:

Multiple authorities have upheld the agency’s interpretation of this statute. See 42 U.S.C. § 1983 (providing for civil action for deprivation of rights); Chevron U.S.A., Inc. v. Natural Res. Def. Council, Inc., 467 U.S. 837, 842 (1984) (establishing the Chevron deference principle); 29 C.F.R. § 1602.14 (EEOC regulations on recordkeeping).

This example demonstrates integrating different legal sources while ensuring clarity and proper organization.

Following these examples will help legal writers construct clear, effective, and professionally formatted string citations. By paying attention to the hierarchy, relevance, and clarity of citations, legal arguments can be presented more convincingly. In the concluding section, we will wrap up our discussion on mastering the art of string cites.

Conclusion: Mastering the Art of String Cites in Legal Writing

Mastering complete citations in legal writing is essential for constructing persuasive, credible, and professionally compelling legal documents. This practice encapsulates several critical elements of effective legal writing, including rigorous research, meticulous adherence to citation guidelines, and strategic presentation of legal authorities.

By understanding the importance of string citations and following the best practices, legal writers can significantly enhance the clarity and strength of their arguments. To recap the key takeaways from this article:

• String citations are tools used to support legal propositions with multiple authoritative sources, adding weight and depth to arguments.
• The importance of string citations lies in their ability to reinforce authority, showcase thorough research, establish precedent consistency, and enhance the persuasiveness of legal writing.
• Effective guidelines for using string citations include following citation guides precisely, prioritizing the most authoritative sources, using logical order, avoiding citation overload, ensuring each source adds value, integrating string cites smoothly, and using parentheticals for context.
• Common mistakes to avoid in string citations encompass overloading sentences with citations, using irrelevant or weak sources, inconsistent formatting, lacking parentheticals, ignoring the hierarchy of authorities, and errors in punctuation and italics.
• Examples of properly formatted string citations illustrate the correct structure and presentation, demonstrating the integration of cases, statutes, secondary sources, and administrative regulations.

Consistently applying these principles will result in clear, well-supported, and compelling legal arguments, increasing the effectiveness of legal advocacy. Remember, the goal is not to overwhelm the reader with a sheer volume of citations but to deliver a thoughtfully curated chain of authoritative sources that convincingly support the legal proposition.

As with any legal skill, mastering string citations requires practice and attention to detail. By continuously refining your citation practices, you can elevate your legal writing to a higher standard of professionalism and effectiveness. For further tips and resources on improving your legal writing skills, consider enrolling in specialized courses such as our course, Legal Writing Launch, where you can gain expert insights and personalized feedback.

In conclusion, whether you are a novice legal writer or an experienced practitioner, the art of using string cites effectively is a valuable skill that can significantly impact the quality and persuasiveness of your legal documents. Invest the time to master this practice, and you will enhance your ability to advocate successfully and professionally in any legal context.