How do I cite a quote from a case that is quoting another case?

Answered by The Citation Code teamOctober 29, 2026

The sentence you want is in a recent opinion, but part of it sits inside quotation marks because that court was quoting an older case. Which case goes in your citation? What happens to the inner quotation marks? And where does the older case go?

If your court, journal or professor handles this differently (for instance, by asking you to cite only the older case), reply below so members can compare.

The team’s answer

Short answer. Cite the opinion you read and are quoting, at the page where your words appear. Keep the older court’s words in single quotation marks inside your double ones, and name the older case in a parenthetical: (quoting Older Case, full citation). Cite the older case by itself only once you have read it and it supports your point.

The rules behind it
[Convention] “Quoting” tells the reader that the opinion you cite took those words from the earlier source. “Citing” says it relied on that source without quoting it. The two are not interchangeable.
[Convention] Quotation marks alternate: double marks around your quotation, single marks around any quotation within it.
[Convention] Cite the older case in full the first time your document mentions it. The opinion you quote may use a short form for it because it cited the case earlier; your reader never saw that earlier citation.
[House style] Keep the inner marks and say whose words they are. Notes about your own changes, such as (emphasis added), go before the (quoting ...) parenthetical. Courts are not consistent about this order, so follow your court’s or journal’s guide.

One phrase, two Supreme Court opinions (each read in the official text)
1. United States v. Moore, 95 U.S. 760 (1878), wrote on page 763 that the construction given to a statute by those charged with executing it “is always entitled to the most respectful consideration, and ought not to be overruled without cogent reasons.”
2. Loper Bright Enters. v. Raimondo, 603 U.S. 369 (2024), quoted pieces of that same sentence on page 386 — “the most respectful consideration,” the officers as “masters of the subject,” and “the draftsmen of the laws” — in its history of how courts once treated Executive Branch readings of statutes, and cited Moore at 763.

The chain shows why the choice of source matters. Moore’s own sentence goes on to say that such a reading “ought not to be overruled without cogent reasons.” Loper Bright took only pieces of it and, a few lines later, said in its own words that the Executive Branch’s views “could inform the judgment of the Judiciary, but did not supersede it.” Quote the opinion that actually says what you need, and read it first.

In your own brief, quoting Loper Bright
The Court has recalled that it once “gave ‘the most respectful consideration’ to Executive Branch interpretations.” Loper Bright Enters. v. Raimondo, 603 U.S. 369, 386 (2024) (quoting United States v. Moore, 95 U.S. 760, 763 (1878)).

Use (citing ...) when nothing was quoted. On the same page, Loper Bright said in its own words that this respect was thought especially warranted when the Executive Branch’s reading came out at about the time the statute was enacted and stayed consistent. It supported that with See and three older cases, National Lead among them. A paraphrase of that point, taken from Loper Bright, can end: (citing Nat’l Lead Co. v. United States, 252 U.S. 140, 145–46 (1920)).

Common mistakes
Citing only the older case when you have not read it.
Copying the quoting opinion’s short form for the older case into a brief where that case has not yet appeared.
Writing (citing ...) for words that were quoted, or (quoting ...) for a source that was only cited.
Dropping the inner marks without a note. That option, (internal quotation marks omitted), has its own thread.

How do I cite a quote from a case that is quoting another case?

The team’s answer

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