Build a citation you can explain

Opening problem

An editor sees “Section 107 proves our use is legal.” The citation has no title, code, version, or subsection. The source actually lists factors for deciding fair use. The repair must identify the provision and narrow the sentence to what the inspected text supports.

Learning objectives

Identify constitutional subdivisions; distinguish a code from session laws and annotations; preserve title, section, and subsection information; state version information accurately; and avoid treating a citation as a substantive legal conclusion.

Annotated constitutional model

An ordinary federal constitutional citation uses U.S. Const. followed by the applicable article or amendment and its subdivision. Use art., amend., §, and cl. where the provision has those divisions. A constitutional article is not a statute title; an amendment number is not a reporter volume.

Article III, section 1 vests the federal judicial power in a supreme court and inferior courts Congress may establish. U.S. Const. art. III, § 1. The article and section locate the constitutional text. A claim about how a court has interpreted it would require the relevant decision.

State constitutions use the state abbreviation and the provision's actual subdivision system. Do not convert every state locator into federal article/section/clause structure. Historical constitutional provisions may need a year or an explanatory notation showing amendment or repeal. Preserve which version you inspected. An obsolete provision can be a proper historical source without being present law.

Statutes: title, code, and section

A federal code citation ordinarily identifies the title number, U.S.C., and the section. Subsections extend the locator: § 107(1) differs from § 107 as a whole. The title number tells the reader which major subject division of the code to consult. The section number alone is often insufficient because the same number can occur in several titles.

Model: 17 U.S.C. § 107(1) (2024).

The 2024 provision identifies purpose and character of the use, including commercial or nonprofit educational character, as one listed fair-use factor. Describe that factor accurately: it does not make commercial uses automatically unlawful or educational uses automatically lawful. The citation identifies the 2024 edition; a claim about a later period needs the applicable text.

Distinguish a citation to a current code from one identifying a historical version. A current provision may not need a year under its baseline; a historical citation must identify the relevant version. Our explicit 2024 parenthetical identifies the edition actually inspected. It is not a rule requiring that year for every current citation.

Dates answer different questions

An enactment date identifies when legislation became law. An effective date identifies when its provisions operate. A code edition year identifies a publication/version. A website retrieval date identifies when you accessed a page. None can be silently substituted for another.

When an event occurred before an amendment, the governing version may be historical. Find the provision and amendment history applicable to that event. Save the text used and identify its date. Do not cite the current page and describe the old text unless the page actually supplies that historical version.

A supplement can modify a bound code's text. Identify the relevant publication information when citing a bound volume with a supplement. A code page carrying an “effective through” statement needs that statement recorded in the research card. Current website availability is not evidence that the text governs every historical event.

Official and annotated codes

An annotated code includes editorial features such as case notes. Those features help research but are separate from the enacted provision. A citation to the statute supports the statute's text; a citation to an annotation does not make the annotation law. If you use a publisher's commentary, identify and cite that secondary material appropriately rather than attributing it to the legislature.

State codes vary in titles, chapters, acts, articles, and section layouts. Illinois ILCS numbering, for example, has chapter/act/section information. California uses subject codes. Use the actual state's structure and receiving-court rule. A federal U.S.C. pattern is not a universal state-code template.

The state reference material preserves both uniform-style entries and local notes, sometimes using different abbreviations. That distinction matters: the table's general Ill. Comp. Stat. form differs from the ILCS local form addressed by Illinois Rule 6. Do not silently blend a uniform citation table with a jurisdiction's instruction.

Session laws and named acts

A session law identifies legislation as enacted, often by public-law or chapter number and session-law publication. A codified provision identifies its organized location in a code. Use session laws when the enactment itself, an uncodified provision, an amendment, or historical text is the relevant source.

A popular act name can help identify legislation but does not necessarily replace title/code/section information. An act may affect many sections. If your proposition concerns one subsection, locate it rather than citing the act's name as though it were a pinpoint. Chapter 13 expands session laws and legislative materials.

Short forms

An unambiguous code-and-section reference can often be shorter after a full identification. Preserve enough information to distinguish multiple titles or codes. Id. follows its own immediately-preceding-source rule; do not use it to skip an intervening case citation. Supra is generally unsuitable for statutes under the citation convention used here.

For section ranges, preserve subsection boundaries and use §§ when citing multiple sections. A range from subsection (a) through (c) is not a range from sections 1 through 3. Write the actual locator carefully, including parentheses and hyphens. A malformed subsection can redirect the reader to a different legal command.

Worked repair

Replace “Section 107 proves our use is legal” with an edition-specific, supported observation: “The inspected 2024 Code lists the purpose and character of the use among the fair-use factors. 17 U.S.C. § 107(1) (2024).” Evaluating a particular use requires more than this factor's existence. The repair removes an unsupported outcome claim while supplying a reproducible locator.

Common mistakes and repairs

Compact reference

Identify constitution/code/session law → collect jurisdiction and divisions → select precise provision → identify version → separate text from annotations → verify the sentence → check receiving requirements.

Worked editing session: choose the applicable statutory version

Fictional training example — not legal authority. Harbor Code title 8, § 20(b), in the supplied 2023 edition requires notice within ten days. A 2025 amendment changes the period to fourteen days and says the change applies to requests submitted on or after July 1, 2025. The dispute concerns a request submitted April 1, 2025. Assume no other amendment or transition provision affects this packet.

Place the legally relevant events in order before writing the citation:

The April request falls on the earlier side of the supplied boundary. A useful sentence is: “The version applicable to the April request required notice within ten days. Harbor Code tit. 8, § 20(b) (2023).” The code citation identifies the ten-day wording. If the paragraph also explains why the amendment does not govern, cite the amendment's actual applicability clause as well. Its publication identifier has not been supplied here, so the packet supports the temporal analysis but not an invented full amendment citation.

The distinction matters when a code editor incorporates fourteen days into the current display but leaves the applicability clause in a note or separate session law. Copying the current section would retrieve the new wording without answering the historical question. Recover the earlier section and the provision that tells you when the change applies. A chronological list of amendments is a starting point; the operative words determine the boundary.

Also identify the event used by the transition provision. Here it is the date a request was submitted. A date of injury, hearing, judgment, or research would not substitute for it. A well-dated citation can still accompany the wrong temporal analysis if the writer chooses the wrong triggering event.

Finally, keep two kinds of numbering apart. Section 3 of an amending act might replace subsection (b) of code section 20. To describe the enacted amendment, locate section 3 of the act. To quote the reorganized code text, locate § 20(b) of the code. Do not create “§ 3(b)” by combining half of each address.

Advanced workshop: keep the statutory address intact

A statutory address is a hierarchy. Read it from the largest unit to the smallest before shortening it. In 17 U.S.C. § 107(1) (2024), the 17 identifies the code title, 107 the section, and (1) a subdivision within that section. A familiar act name can be useful prose, but it does not replace that address. Two different enactments can amend the same code section, while one enactment can amend many code sections.

Fictional training example — not legal authority. A supplied Harbor enactment has section 3, which inserts Harbor Code title 8, section 20; the new code section contains subsections (a), (b), and (c). A draft calls the notice rule “section 3(b) of the Harbor Code.” That combines the enactment's section number with the code's subdivision. The packet places the operative notice rule in Harbor Code tit. 8, § 20(b) (2025). If discussing how the enactment changed the code, identify the enactment's section 3 separately. A correct number copied from the wrong layer remains an incorrect locator.

Use the plural symbol for multiple sections, not merely for several subdivisions of one section. Under this book's house convention, a reference to the two supplied subsections is Harbor Code tit. 8, § 20(b)-(c) (2025). A reference to two separate sections would use §§ followed by those section numbers. Repeating complete subsection addresses is preferable when a compressed range might obscure the hierarchy. Never collapse (b)(1) and (b)(3) into (b)(1)-(3) if you mean only those two nonconsecutive provisions rather than the intervening provision as well.

Ranges require two further checks. First, decide whether the punctuation belongs to the section number: a state provision numbered 12-104 has an internal hyphen. Second, decide whether the author means an inclusive range or a list. A source citation is not the place to guess that everything between two selected sections also supports the proposition. For distant or nonconsecutive provisions, list the actual locators. For a provision spanning an exceptionally long section, select the subdivision that contains the rule and any material exception.

Federal and state publication years

A year is optional for a current United States Code citation. The state-code pattern calls for the edition or publication year, while acknowledging that local practice may omit it. Do not generalize the federal no-year convention to every state code. A historical federal provision needs a historical version; a state model using this convention ordinarily needs its edition year even when discussing the current code. An applicable receiving rule can alter that presentation.

The publisher field has a similarly limited function. A current U.S.C.A. citation identifies West and a U.S.C.S. citation identifies LexisNexis. That field identifies the publication consulted. It does not identify Congress as having written the publisher's notes. State codes have their own publisher requirements, so consult the state entry and the actual source. Do not append a commercial publisher to an official-code citation merely because the research began in a commercial search interface.

For an edition plus supplement, collect the base edition and relevant supplement designation together. Then determine whether the relied-on text appears in the base volume, the supplement, or both. A parenthetical describing both is useful only when it accurately identifies the source used. Copying a supplement year from a neighboring provision can misidentify the applicable text. If the electronic source supplies a currency-through statement rather than a volume title page, preserve that statement as given; do not manufacture a printed supplement designation.

Constitutional and statutory short forms

Constitutions have a tighter rule than many sources. The constitutional convention calls for the full constitutional citation each time, with id. permitted for sequential citations to the same constitutional provision. It does not authorize a general constitutional supra form. Repeating U.S. Const. art. III, § 1 is short enough to keep the source unambiguous and maintains the supplied article/section address.

For code short forms, an eligible Id. can refer to another section within the same title when the new section is stated. A move to a different code title calls for more identifying information to identify the new title. Even an otherwise permitted short form fails if the surrounding paragraph has made its referent uncertain. Check the last cited source in the final document order, the code title, and the new provision together. These three checks prevent a visually tidy reference from redirecting the reader to the wrong law.

Source laboratory: read the provision beneath the running header

A statutory PDF can contain more than the section named in its download link. The inspected 2024 Code file for 1 U.S.C. § 112 begins on printed page 12, whose running header identifies § 111. The body then presents § 112, followed by amendment notes and related statutory notes. The next sheet also contains § 112a. A search result, filename, and running header are useful navigation aids; the section heading and text determine which provision you are reading.

The operative paragraph of § 112 directs the Archivist to compile and publish the United States Statutes at Large and specifies the collection's legal-evidence function. A carefully bounded model sentence is: “The inspected statutory text directs publication of the Statutes at Large and identifies the collection as legal evidence of the materials specified in the provision.” 1 U.S.C. § 112 (2024). The citation uses the section, not the PDF viewer's page 1, because a statutory section is the relevant legal address. The edition parenthetical records the version inspected.

The sentence does not say that every law printed in every historical volume remains operative. Publication identity and continuing effect answer different questions. A 2010 public law remains an identifiable 2010 enactment even if later legislation changes one of its provisions. The publication can establish what the historical enactment said; it cannot, by that fact alone, establish the wording applicable to a later event.

Read the material following the operative paragraph by category. The file labels amendment history separately from statutory notes. An amendment note can direct research toward the changing text. A quoted statutory note may reproduce separately enacted language with its own public-law and section identifiers. Neither should be casually merged into the section's operative paragraph. If a proposition depends on a note, identify the underlying source and inspect its language rather than assuming every sentence on the page belongs to § 112 itself.

For a historical problem, construct a small version table before drafting. Use columns for the event date, source edition, relevant amendment, effective or transition provision, and the passage actually relied on. Leave a field unresolved if the source does not answer it. This table is a research device, not part of every finished citation. Its purpose is to keep a clean-looking citation from concealing an unsupported choice of law in time.

Test the finished sentence. First ask whether you are describing a publication, an enacted provision, or the law governing a dated event. Next ask whether the selected source proves that precise thing. Only then compress the source identity into a citation. Compression should shorten a verified route to the text, not erase the distinction that made the route correct.

Takeaway

Provision numbers and version dates are part of the source's identity. A correct locator supports analysis; it does not decide the legal outcome for you.

Chapter source note

Citation conventions draw on The Indigo Book 2.0, R16–R17, R23, T1, and T3, including differing federal/state date conventions and repeated constitutional references.

Real examples use the National Archives Constitution transcription, Article III, § 1; 17 U.S.C. § 107 (2024), printed page 26; and 1 U.S.C. § 112 (2024), printed pages 12–13. The Code examples identify those historical editions; they do not establish later amendment history.