41. Citation Sentences, Clauses, and Notes

These chapters supply Citation Code's explicit editorial defaults where the recipient leaves a choice. They develop the shorter guidance in chapter 6, chapter 7, chapter 8, and chapter 33. They do not describe every court's requirements. Apply a receiving instruction within its scope and record the exception; do not change source identity or meaning to accommodate a style preference.

Training-source convention. Every person, organization, tribunal, work, document, quotation, date, and source identifier invented in the examples below is fictional. TRAIN-… identifiers deliberately distinguish training objects from real legal authorities. No invented case is assigned a real reporter citation. Examples stipulate what their sources contain; they establish no real legal proposition. The named house rules, layouts, and editorial thresholds are original choices for this reference. They are not attributed to another citation manual.

41.1 Choose the attachment before writing the reference

Treat a citation as an address attached to a claim. The attachment must tell the reader which words the source supports. Our default is one citation unit for one proposition or a closely related set of propositions supported by the same passage. When a sentence changes from describing a record to stating a rule, begin a new support unit. When it moves from a rule to an inference about facts, identify the factual premise as well as the rule.

Use three available constructions deliberately. A citation sentence follows the proposition as a separate unit, begins with a capitalized signal when one is needed, and ends with a period. A citation clause sits inside a grammatical sentence, usually after the supported clause, and begins with a lowercase signal. A source integrated into prose names the work as part of the sentence and places the remaining reference next to that name or at the sentence's end. Choose among them for attachment and readability, not to give the same source a different weight.

Before editing punctuation, underline the exact proposition and write its supporting locator beside it. If two underlined claims need different locators, either supply both or split the sentence. A citation to an entire document is adequate for identifying the document as an object, but it is usually a poor attachment for a particular factual or textual assertion.

41.2 Construct a separate citation sentence

Place a period after the substantive sentence. Begin the citation sentence with the source when it directly supplies the proposition, or with the selected signal when the relationship needs explanation. Separate multiple sources serving the same proposition with semicolons. End the unit once, after the last explanatory parenthetical. A period that belongs to an abbreviation is not a substitute for required sentence punctuation when it occurs earlier in the unit.

Fictional training example. The packet's Archive Procedure directs the clerk to assign a receipt number. The completed text is: “The procedure directs the clerk to assign a receipt number. Harbor Archive Office, Archive Procedure § 4 (Jan. 8, 2026).” The source is direct support, so the house default adds no signal. A second source is useful only if it contributes another identified reason, such as demonstrating how the procedure was implemented.

For an inference, write: “The register appears to have been organized by receipt date. See Harbor Archive Office, Intake Register, entries 1–18 (Jan. 2026) (arranging successive entries by recorded receipt date).” The sentence says “appears” because the supplied sequence supports an inference; the parenthetical explains the inferential premise. Changing the signal alone would not justify changing “appears” to “must.”

Do not start a separate citation sentence with a lowercase signal merely because it follows another citation. Each independent unit has its own capitalization. For punctuation within a string, use section 42.4.

41.3 Use a citation clause when the sentence has two distinct jobs

Put a citation clause immediately after the clause it supports. Separate it from the surrounding prose with punctuation that preserves the sentence's grammar. Our preferred construction uses a comma before the citation and a semicolon after it when another independent substantive clause follows. If the reference is long enough to obscure the sentence, split the sentence instead.

Fictional training example. “The intake procedure requires a receipt number, Harbor Archive Office, Archive Procedure § 4 (Jan. 8, 2026); the supplied receipt displays number H-17, Receipt H-17 (Jan. 12, 2026).” The semicolon separates two independently supported propositions. A single citation after the receipt number would not transparently support the procedural requirement.

With inferential support, use lowercase “see” inside the sentence: “The entries suggest chronological intake, see Harbor Archive Office, Intake Register, entries 1–18 (Jan. 2026), but the packet contains no instruction making chronology mandatory.” Here the final qualification is the author's description of the supplied packet. If that qualification is disputed or central, state it separately and identify the scope of the packet examined.

Avoid placing a citation clause between a verb and its object or between a name and its defining phrase. “The office assigned, Procedure §4, a receipt number” makes the reference interrupt the action it is supposed to support. Repair by moving the reference after the complete proposition or by integrating the source into prose.

41.4 Integrate a source into the prose without repeating its name

When the source itself is the subject, name it in the sentence and attach the remaining identity information closely. Use this form to discuss what a work says, compare texts, or introduce an extended quotation. Do not force every source into prose; a reader following the argument should not have to navigate a catalogue of authors before reaching the point.

Fictional training example. “The Harbor Archive Office's Archive Procedure § 4 (Jan. 8, 2026) directs the clerk to assign a receipt number.” The title and provision perform work in the sentence. Repeating the complete title at the end would add no identity. If a footnote supplies access information, it may contain the full source record, but avoid duplicating every element merely to satisfy a visual habit.

For a fictional opinion, write: “In Aster Workshop v. Vale Supply, No. TRAIN-41, slip op. at 7 (North Coast Training Tribunal May 11, 2026), the tribunal described the receipt log.” The construction identifies the writing and the pinpoint before the description. If that descriptive phrase becomes lengthy, state it first and move the citation into a separate sentence.

Distinguish naming a source from supporting a conclusion. “The procedure is mentioned in the memorandum” does not use the procedure for its substantive instructions. Cite the memorandum's relevant passage if the proposition concerns the memorandum's contents.

41.5 Put note markers where their scope is clear

Citation Code's default places a note marker after the punctuation ending the supported sentence or clause. A note supporting only a quoted phrase may follow that phrase and its closing quotation mark before later sentence material. When this creates awkward punctuation or uncertain attachment, rewrite the sentence. The marker should not make the reader guess whether the note supports one word, an entire sentence, or several earlier sentences.

Use a separate note for a materially different proposition when the existing note would become a collection of unrelated support. A note may contain multiple sources, but their internal organization should match the order of the propositions in the text. Begin a mixed-purpose note with a brief explanation rather than an unexplained list.

Fictional training layout. Body: “The procedure requires a receipt number.[1] The receipt supplied in this packet bears H-17.[2]” Note 1 identifies Procedure §4; note 2 identifies Receipt H-17. The bracketed numbers here illustrate marker positions; the production document uses its normal note numbering. A single marker after the second sentence could work only if the note expressly maps the two sources to the two propositions.

Do not place a note marker inside a quotation as though it belonged to the source. If the original contains a note marker, preserve or disclose its omission under section 44.8. The author's new note is a different object.

41.6 Build a note that can be read independently

A source-only note follows the same capitalization and terminal-punctuation rules as a citation sentence. An explanatory note begins with a complete sentence when it contains substantive analysis. Give a source for a new factual or legal assertion made in the note just as you would in the body. The note's location does not reduce the support required by its contents.

Use a short source name only if the note's reader can identify its antecedent under chapter 45. For a note that a reader might encounter through search or a hyperlink, retain a recognizable title and source identifier. A note consisting only of “Id.” may be compact on a printed page but becomes fragile when extracted into a research record.

Fictional repair. Defective note: “Different procedure. Hale 22.” Repaired note: “Hale describes a different procedure that assigns a batch number before individual intake. Noor Hale, Managing Archive Intake 22 (2d ed. 2026).” The revised note identifies the difference and supplies a usable source. It does not ask the reader to infer whether page 22 contradicts the body or merely gives another example.

When a note requires more than one paragraph to resolve an important issue, consider moving the analysis into the body. The choice turns on the issue's importance to the reader, not on whether putting it in a note makes the page look shorter.

41.7 Keep tables, captions, and lists connected to their support

For a table drawn from one source, identify the source in the caption or a table note and specify the covered columns. If one column contains the author's calculation, label that transformation separately. If rows come from different sources, put a source or keyed reference in each row. A note under a table should not imply that every entry came from the last source consulted.

Fictional training example. A three-row chronology uses Receipt H-17 for receipt, Register entry 18 for logging, and Dispatch Record D-8 for transfer. A source column gives those identities and locators in the corresponding rows. The table title “Archive intake chronology” is the author's title, not a source quotation. If the final column reports elapsed days, label it “Author's calculation from displayed dates” and state the calculation convention when it matters.

For a list, place a reference after each item unless one introductory reference clearly covers the entire list. For an image or diagram reproduced from a source, a citation identifies provenance; it does not itself resolve reproduction rights. For an original diagram based on several documents, say which documents supply the underlying facts and distinguish the author's arrangement.

41.8 Apply the attachment test to a complete repair

Fictional initial paragraph. “The procedure requires a receipt number, the clerk received the packet on January 12, and the transfer was therefore timely. Harbor Archive Office, Archive Procedure § 4 (Jan. 8, 2026).” The packet supplies Procedure §4 on numbering, Receipt H-17 on receipt, and Procedure §9 requiring transfer within five calendar days after receipt. Dispatch Record D-8 records transfer January 15. For this exercise only, the supplied procedure expressly counts the day after receipt as day one and supplies no exception.

Repaired paragraph. “The procedure requires a receipt number. Harbor Archive Office, Archive Procedure § 4 (Jan. 8, 2026). The clerk received this packet on January 12 and transferred it on January 15. Receipt H-17 (Jan. 12, 2026); Dispatch Record D-8 (Jan. 15, 2026). Under the packet's stated counting method, that transfer falls within its five-calendar-day interval. Harbor Archive Office, Archive Procedure § 9 (Jan. 8, 2026).”

The repair supplies the missing rule and facts, rather than attaching more titles to the original sentence. The final inference is explicitly confined to the stipulated method. The same discipline applies when a real question requires a complex legal calculation: construct the support chain first, then choose the most readable placement.