This continues the examples started here about using Citrus automatic Bluebook legal citation software. This example contains small portions of a brief about a case involving allegedly threatening speech.

Automatically Putting Existing Citations into Bluebook Format

If you are working with a document that already has citations that were not entered with Citrus, you can easily mark them and use Citrus to automatically keep them in Bluebook format as you continue editing the document. The same technique also works if you enter a citation but forget to press F2. Simply use your mouse or keyboard to highlight the citation, then press F2. Try entering the following sentence into your document now:

Political speech per se cannot provide a basis for civil liability, 458 US 886, 933-934, so it cannot provide the basis for criminal liability, 397 US 358, 364.

Highlight "458 US 886, 933-934" and press F2, then do the same with "397 US 358, 364". Citrus will automatically generate the correct Bluebook citations in the sentence:

Political speech per se cannot provide a basis for civil liability, NAACP v. Claiborne Hardware Co., 458 U.S. 886, 933-34 (1982), so it cannot provide the basis for criminal liability, In re Winship, 397 U.S. 358, 364 (1970).


Using Abbreviations and Shortcuts

Citrus can also help you enter case citations more quickly. To see how, follow the steps in the rest of this introduction.

Use your mouse or cursor to highlight all of the text in the document and delete it to start with an empty document. Type the first sentence again:

The Court held that the speech could not be considered a true threat.

Now press F2 and enter the citation, but this time enter just the reporter citation from the U.S. reporter:

394 US 705, 708.

When you press F2 to tell Citrus that you are done entering the citation, Citrus automatically expands the reporter citation to a full case citation in Bluebook format including parties, correct reporter citation, year, and per curiam as shown below. (At this time, Citrus can do this only for U.S. Supreme Court cases.)

Watts v. United States, 394 U.S. 705 (1878) (per curiam).

In general, Citrus does not require you to enter periods, so Citrus correctly recognizes the reference to "US" rather than "U.S." in the cite above. Correct spacing and capitalization are also generally not required, so you could also have entered this:

394us705,708

That would also have produced this citation:

Watts v. United States, 394 U.S. 705 (1878) (per curiam).

Remember that Citrus recognizes Watts by its reporter cite, 394 U.S. 705, because Watts is a Supreme Court case. Citrus will not recognize other cases solely by their reporter cites.

A Note on Using Abbreviations and Shortcuts to Avoid Errors


Having Citrus generate the full case citation for Supreme Court cases can often save you from citation mistakes. For example, if you use Westlaw to pull up the classic Pennoyer v. Neff by its citation, you will see a reference to the October 1877 term. You will see the same date in the print edition of the U.S. reporter.

However, citing that case as Pennoyer v. Neff, 95 U.S. 714 (1877) is wrong. The case citation rules require that you cite to the date of decision. The reference to 1877 is a reference to the term of the court, which started at the end of 1877 and ran through the beginning of 1878. To find the date of decision, which is January 21, 1878, you have to look in the Supreme Court Reporter or in a special list of decision dates on the U.S. Supreme Court web site.

However, if you simply use F2 95 us 714 F2, Citrus will automatically generate the correct cite:

Pennoyer v. Neff, 95 U.S. 714 (1878).


At present, Citrus will only retrieve case data about cases from the U.S. reporter. However, Citrus will still format and manage citations from other sources. Try the following sentence and legal citation:

Courts are far more resistant to criminalizing public political speech than speech in private communications. See, e.g., Melugin v Hames 38 f3d 1478,1484(9thcir, 1994).

If you did not press F2 while entering the citation then highlight "See, e.g., Melugin v Hames 38 f3d 1478,1484(9thcir, 1994)." and press F2. Citrus will automatically generate the following Bluebook citation in its place:

See, e.g., Melugin v. Hames, 38 F.3d 1478, 1484 (9th Cir. 1994).



Click here to see a brief demonstration of Citrus legal citation software automatically managing legal citations.