The Citation Code

Original research draft · October 2026

1. Start with the Reader's Task

1.1 Write the proposition before choosing the form

Ask what the sentence needs the source to establish. A sentence about the text of a statute needs the applicable statutory text. A sentence about a court's construction of that text needs the judicial discussion. A sentence about what a witness said needs the relevant testimony. Sometimes a sentence needs two sources because it makes two claims. Identify those claims before adding a long citation string.

Consider this fictional draft: “The tenant notified the owner on June 3, so the notice was timely.” A letter might establish when the tenant sent notice. The governing agreement or law might establish the time limit. A delivery record might establish when the owner received it. One citation to the letter cannot silently prove all three matters. Separate the factual statement from the legal conclusion and cite each supporting item.

Citation is therefore part of analysis. When no source supports the full sentence, change the sentence or continue researching. Do not solve the problem by making the citation longer.

1.2 Use four checks

Our core method is identity, location, support, and status. Identity asks whether the document is the one named. Location asks whether the reader can reach the passage. Support asks whether the passage justifies the claim. Status asks whether the material can perform that role in the present task.

These checks catch different errors. A case with the right name and wrong reporter page fails identity. A twenty-page citation for a one-sentence quotation may fail location. A dissent cited as a holding fails support. A vacated opinion described as controlling may fail status. Passing one check does not excuse failure of another.

Keep a short note for each important authority: the proposition, the passage, its location, and any qualification. This note becomes a reusable research asset. A bare citation in a list does not preserve the reason you thought the source mattered.

1.3 Match effort to the source's role

A central authority deserves a full source and history review. Background material still needs verification, but its research record may be simpler. Allocate effort by consequence: a jurisdictional statement, a dispositive standard, a numerical deadline, and a quotation supporting the requested relief should not depend on a search-result snippet.

If you discover the same proposition in an article and in a judicial opinion cited by the article, read the opinion before representing the proposition as the court's reasoning. The article may have summarized, criticized, or limited it. If you cannot obtain the original, identify the intermediary and avoid implying a direct reading.

1.4 Give the citation a clear attachment

Place the reference close enough to the proposition that its coverage is clear. A footnote at the end of a paragraph can be adequate for a coherent proposition, but it can become ambiguous when the paragraph contains several facts and legal conclusions. Split the paragraph or place references after the relevant clauses.

Do not assume that a citation to the last sentence supports everything before it. During review, draw an imaginary line from each citation to the exact language it supports. If the line cannot be drawn confidently, revise the attachment.

Working example — fictional. Draft: “The agency received the application in March. Its rules required a signed certification. The company qualified for an exception.” Repair the citation plan by assigning a receipt record to the first sentence, the rule provision to the second, and the exception's text plus the qualifying facts to the third. A single citation after “exception” hides the separate evidentiary work.