Signals and parentheticals

Signals describe the support

No signal: the source directly states your point, or you quote it. E.g.: one of several sources that directly support it. Accord: a second source that states the same point as the first. See: the source supports the point by an obvious inference. See also: additional support. Cf.: supports by analogy.

Compare … with …: comparing sources illustrates the point. Contra: directly contradicts. But see: contradicts by inference. But cf.: contradicts by analogy. See generally: helpful background.

Order and punctuation

Signals appear in this order: supporting signals (no signal, e.g., accord, see, see also, cf.), then comparison, then contrary signals (contra, but see, but cf.), then see generally.

Separate signals of the same type with semicolons inside one citation sentence. Start a new citation sentence when the type changes. In court documents, italicize signals. Capitalize a signal only when it begins a citation sentence.

Changing type

See Terry v. Ohio, 392 U.S. 1, 21 (1968). But see Mapp v. Ohio, 367 U.S. 643, 655 (1961).

Explanatory parentheticals

An explanatory parenthetical tells the reader why the source matters. Begin with a present participle (holding, finding, explaining, noting), start lowercase, and leave out the final period. You may also quote a full sentence instead.

Parentheticals follow a set order: court and date; weight of authority such as (en banc) or (per curiam); notes about changes to a quotation such as (emphasis added) or (internal quotation marks omitted); (quoting …) or (citing …); the explanatory parenthetical; then subsequent history.

The current edition also accepts (cleaned up). It tells the reader you removed internal quotation marks, brackets, or citations from a quotation without listing each change.

Explanatory

Terry v. Ohio, 392 U.S. 1, 30 (1968) (holding that an officer may briefly frisk a person reasonably believed to be armed and dangerous)