6.5.4 Using Effective Sentence Structures to Accommodate Citation Form

Incorporating citations into text is the best way to promote easy identification of the value of your authority. You will help both your reader and your user, however, if you use effective sentence structures to accommodate citations.

BAD EXAMPLE In J.E.B. v. T.B., 511 U.S. 127, 138-40 (1994), this Court held that sex-based peremptory challenges violate jurors’ rights to equal protection.

This sentence is difficult to read because the citation takes up a lot of space within the sentence. Furthermore, this structure puts too much emphasis on the citation and not enough emphasis on the substance of the sentence. To solve this problem, some writers mistakenly separate the case name from the rest of the citation:

BAD EXAMPLE In J.E.B. v. T.B., this Court held that sex-based peremptory challenges violate jurors’ rights to equal protection. 511 U.S. 127, 138-40 (1994).

This “separated long-form” or “split cite” structure is also not optimal. Although some citation rules may condone this separation, it can annoy the reader, who might well be confused at encountering a case name with no citation information. The reader’s immediate thought is that the case must have appeared earlier and is now being cited in short form. Upon reading the end of the sentence and finding long-form information, the reader has to reconsider his or her reaction to the case. It is best to avoid this little mental drama by writing a readable sentence that puts the citation in a separate citation sentence:

GOOD EXAMPLE This Court has held that sex-based peremptory challenges violate jurors’ rights to equal protection. J.E.B.

This structure lets the citation do its work of telling the reader the name of the case, the court, and the year of decision, but keeps it from intruding on the sentence itself. Including a case name alone in your sentence is appropriate only if you have already cited the case in full in that same discussion:

GOOD EXAMPLE

This Court has held that sex-based peremptory challenges violate jurors’ rights to equal protection. J.E.B. v. T.B., 511 U.S. 127, 138-40 (1994). In J.E.B., the Court found peremptory challenges invalid because they were based on broad assumptions about men’s and women’s relative capabilities. Id.

Thus, structure your sentences so that all citations, and particularly long-form citations, can be placed in their own citation sentences. You can accomplish this goal by keeping the focus on the substance of the cited material rather than on the citation.