How do you cite a footnote in a court opinion?
The point you need is in a footnote, not the body of the opinion. Where does the note number go, is it "n." or "fn.", is there a space, and what if the footnote runs onto the next page?
If you have found a footnote problem this does not cover (endnotes, a slip opinion, a Westlaw cite), reply below.
The team’s answer
Short answer. Give the page on which the footnote starts, then "n." touching the number: 592 U.S. 209, 215 n.3. For two or more notes, write "nn." If the sentence you rely on is in the part of a long note that spills onto the following page, give both pages.
The rule [Convention]
Start the pinpoint from the footnote's first page. That page carries the note's number, so it is where a reader looks first. Then "n." with no space before the digits, or "nn." with a dash or commas for more than one note. To cite a passage of text together with its footnote, join them with "&" ("[page] & n.[note]"). Skip "fn.", "footnote" and "p." inside the citation.
[House style] When a note carries over and the words you need are on the second page, cite the span across both pages. A note's final page on its own sends the reader to the wrong place.
Examples (each checked against the U.S. Reports or the Court's own print)
A footnote on one page:
Brownback v. King, 592 U.S. 209, 215 n.3 (2021).
A footnote that begins on one page and continues on the next, where the point is in the continuation:
Medo Photo Supply Corp. v. NLRB, 321 U.S. 678, 681–82 n.1 (1944).
A footnote in a concurrence. In the U.S. Reports a concurrence or dissent starts its own notes again at 1, so say whose note it is:
Loper Bright Enters. v. Raimondo, 603 U.S. 369, 430 n.4 (2024) (Gorsuch, J., concurring).
A short form after a full citation:
Brownback, 592 U.S. at 215 n.3.
Why the Supreme Court looks different. When Loper Bright cited Medo Photo at page 387, the Court printed "321 U. S. 678, 681–682, n. 1": a comma before the note, a space after "n.", and every digit of the page span. That is the Court's own house style. In a brief or memo following the national form, write 681–82 n.1. Your court's rules can override either, so check them.
Common mistakes
"682 n.1" for a note that starts on 681. The reader looks for note 1 on page 682 and finds only its tail.
"215, n. 3" or "215 fn. 3" in a brief that follows the national form.
A note from a dissent or concurrence with no opinion parenthetical. Without it, the reader assumes it is the majority's note 4, which may say something else entirely.
A page taken from the slip opinion. Pages change between the slip opinion and the bound reports, so find the passage, and its note, again in the version you cite.
Read more
The Pinpoints chapter (its opening is free to read): https://citationcode.com/book/pinpoints (opens in a new tab)
Real pinpoint examples, each checked against its source: https://citationcode.com/examples/pinpoint-citations (opens in a new tab)
Find the page or footnote that holds a quotation, in cases from the scanned printed reports: https://citationcode.com/tools/pinpoint (opens in a new tab)
The sources for the carried-over note and the Court's own form: https://www.govinfo.gov/content/pkg/USREPORTS-321/pdf/USREPORTS-321-678.pdf (opens in a new tab)
https://www.supremecourt.gov/opinions/23pdf/603us1r54_o7jp.pdf (opens in a new tab)