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How to Cite a Memo With a Bluebook


Although proper citation is important in any field of study, legal writing depends heavily on the proper use of citation to establish authority. Citations identify the document to which the writer refers, provide enough information for the reader to locate the document and assist the reader in determining whether or not to track down the article. Legal writers use citations to prove the strength of their argument by establishing its legal authority or precedent. The most common set of rules for legal citation is "The Bluebook," currently in its 19th edition. Learning how to cite a memorandum according to the "Bluebook" allows you to support your argument with the memo.

Follow standard practice for placing references in your writing. If you are writing a legal memorandum or appellate brief, cite the memo within the text. Use footnotes in other forms such as law review articles.

Begin the citation with the standard citation for the case to which the memo is attached. For example, when citing a memo from the Supreme Court case of Community for Creative Non-Violence Et Al., v. Reid, start with "Cmty. For Creative Nonviolence v. Reid, 490 U.S. 730 (1989)." Give the title of the case, the case reporter location and the year of the case.

Insert an opening parenthesis "(" after the year of the case. Type the abbreviation "Mem." to indicate that you are referring to a legal memo.

Type "at" followed by the page number within the memorandum to provide the reader with an exact location, but do not include the word "page."

Include the court case management system document number, such as the federal courts' CM/ECF, if available. For example: ECF No. 21.

Add a closing parenthesis to end the citation: (Mem. at 30, ECF No. 21.)

About the Author

Sean Butner has been writing news articles, blog entries and feature pieces since 2005. His articles have appeared on the cover of "The Richland Sandstorm" and "The Palimpsest Files." He is completing graduate coursework in accounting through Texas A&M University-Commerce. He currently advises families on their insurance and financial planning needs.

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