42. Signals, Strings, and Source Order

42.1 Assign one primary relationship to each source

For each source in a citation unit, complete the phrase “this source is here because it…” with one of six functions: states the proposition, supports an inference, adds support, supplies an analogy, conflicts with the proposition, or provides background. Those functions determine our signal choices. They do not determine whether a source is binding, current, admissible, or permitted in a forum; those are separate questions addressed in chapter 19 and the receiving-rule profiles.

Use no signal for a source that directly states the attributed proposition or contains the quoted words. Use See for a supported inference. Use See also for additional support after a sufficiently supported proposition. Use By analogy, see for a materially different setting whose reasoning you explain. Use But see for relevant conflicting support when the conflict is clear. Use For background, see for contextual material that is not offered as proof of the sentence. Use Compare … with … when the comparison itself is the reader's task.

This vocabulary favors explicit English relationships. A receiving style may prescribe shorter or different signals. Translate the presentation when required, while retaining the source's actual role. Do not write a string first and distribute signals afterward; that approach encourages decorative labels that the sources cannot sustain.

42.2 Distinguish direct support from an inference

No signal is appropriate when the statement accurately reports what the source states. That does not require a quotation. A faithful paraphrase can be direct attribution. “See” is appropriate when the writer asks the reader to connect the cited facts or reasoning to a proposition the source does not expressly state. Explain a nonobvious inference in prose or a parenthetical.

Fictional paired example. Source facts: Intake Register entries 1–5 show January 3, 4, 5, 8, and 9 in that order; the register says nothing about office policy. Direct statement: “The first five entries list successively later receipt dates. Harbor Archive Office, Intake Register, entries 1–5 (Jan. 2026).” Inferential statement: “The clerk appears to have arranged those entries chronologically. See Harbor Archive Office, Intake Register, entries 1–5 (Jan. 2026).” Unsupported statement: “The office requires chronological registration.” Neither signal repairs that last statement because the packet supplies no such instruction.

A source can perform different roles in different sentences. A case directly supports a statement about its own holding and may support an analogy in another dispute. A scholarly article directly supports an attribution to its author but is not automatically direct authority for every underlying legal claim it discusses. Classify the proposition, not merely the source category.

42.3 Use additional support only when it adds something

“See also” means that the proposition already has support and the additional source contributes a distinct reason to include it. State that reason when it is not apparent: another setting, a later explanation, a contrasting factual detail, or a second independently relevant example. A second access copy of the same document ordinarily does not provide additional substantive support.

Fictional training example. “The office assigned a separate identifier to each received packet. Harbor Archive Office, Intake Register, entries 1–5 (Jan. 2026). See also Lena Ortiz, Intake Review Memorandum 3 (Feb. 2, 2026) (describing the same practice during the following month).” The memorandum adds a later observed period. It would not belong merely because its title contains the word “intake.”

Do not begin with “See also” when there is no identifiable primary support in the current citation unit or immediately associated discussion. The reader should not have to search earlier pages for the proposition's foundation. If the source itself directly supplies the newly stated proposition, use direct citation. If the source supports an inference, use “See.”

For cumulative sources, ask what the reader would lose if the last source were removed. If the answer is nothing except a longer list, remove it. Brevity here improves reliability by concentrating review on authorities that actually matter.

42.4 Use punctuation that exposes the group structure

Our default is one signal per group of sources with the same relationship. Italicize the signal words; keep the following citation text in its source-appropriate typeface. Place no comma after “See,” “See also,” or “But see.” The phrases “By analogy, see” and “For background, see” include the displayed internal comma. Separate sources within the same group with semicolons.

Begin a new citation sentence when the relationship changes. This deliberately avoids a dense chain in which semicolons must distinguish both individual sources and different support functions. A compact note can therefore contain a direct-support sentence, an additional-support sentence, and a contrary-source sentence, each with a visible job.

Fictional model. “The two instructions use different triggers. Harbor Archive Office, Archive Procedure § 9 (Jan. 8, 2026); Valley Record Center, Transfer Instruction § 6 (Feb. 3, 2026). For background, see Noor Hale, Managing Archive Intake 41–43 (2d ed. 2026) (describing receipt-based and dispatch-based workflow measures).” The semicolon groups the compared instructions; the new sentence identifies commentary as background.

Do not place a comma between a signal and a source merely because the source starts with an author's name. Do not capitalize a signal embedded inside a citation clause unless it begins a grammatical sentence. For the distinction between sentence and clause, use sections 41.2–41.3.

42.5 Order sources by their work, then by stable tie breakers

First identify the source that most directly establishes the point in the actual receiving context. Put it first. Follow with sources that add a distinct explanation or application. Do not use chronology, alphabetical order, or database display rank to displace the source that does the essential work. When governing directions prescribe an order, follow that order and make the different roles visible in parentheticals.

For equally relevant sources in our house system, use these tie breakers: prefer the source whose passage most directly matches the proposition; then prefer the source closest to the relevant time or version; then use a consistent chronological order. For a historical-development discussion, chronological order normally means oldest to newest because the sequence itself is the point. For a present research summary, newest to oldest may be more useful, but the writer must not infer greater legal weight solely from recency.

For a comparison across institutions, use the order announced in the prose or a clear alphabetical order by institution when no substantive sequence matters. For enactment and amendment chains, follow the order needed to reconstruct the change. For factual events, use event chronology. These are distinct ordering tasks; a single “newest first” setting cannot solve all of them.

Before retaining more than three sources in one group, ask whether a comparison table or two narrower propositions would be clearer. Three is a review prompt, not a limit on necessary support.

42.6 Explain an analogy and expose its limiting difference

“By analogy, see” announces that the source addresses a different setting. Identify both the useful similarity and the difference that may affect the comparison. A parenthetical may be enough for a minor analogy. If the analogy carries the argument, explain it in the body and use the citation to locate the reasoning.

Fictional training packet. The Harbor Archive Procedure assigns a replacement tracking number when a paper folder is split into two folders. The proposed argument concerns splitting a digital collection. A suitable citation is: “By analogy, see Harbor Archive Office, Archive Procedure § 12 (Jan. 8, 2026) (assigning replacement identifiers after a paper folder is divided).” The prose should then explain why the identification problem is similar and whether the paper procedure's physical-label requirement has a digital counterpart.

Defective wording would be “The procedure requires replacement identifiers for digital collections” when the source mentions only paper folders. Adding “Cf.” or any other signal would not make that sentence faithful. Repair the sentence to identify the analogy itself.

When an analogy depends on several sources, give each source a defined role. A paper procedure may establish a design principle, while a digital system manual establishes the system's available features. Do not imply that either source alone contains the completed recommendation.

42.7 Make a comparison symmetrical

Use “Compare A with B” when the reader needs to inspect a meaningful contrast or similarity. Give A and B parallel levels of specificity: comparable provisions, passages, or versions. Explain what the comparison shows. A comparison of one precisely identified section with an entire unrelated book is difficult to evaluate and often conceals an incomplete research step.

Fictional completed example. “Compare Harbor Archive Office, Archive Procedure § 9 (Jan. 8, 2026) (measuring the transfer interval from receipt), with Valley Record Center, Transfer Instruction § 6 (Feb. 3, 2026) (measuring the interval from registration).” The paired parentheticals identify the difference without implying that one institution's procedure governs the other.

For more than two comparison groups, use a table or separate sentences. If one side contains two sources, join their citations with “and” inside that side and preserve semicolons only for another purpose when unavoidable. Prefer a rewritten sentence over punctuation that requires decoding.

When comparing versions, name the earlier and later versions explicitly. “Compare §4 with §4” has no useful meaning without the instrument dates or version labels. For historical text selection, see chapter 20.

42.8 Present contrary and background sources accurately

Use “But see” only when the cited passage actually conflicts with the proposition or its stated reasoning. Explain the point of conflict. If the source is merely narrower, distinguish that limit in words rather than announcing a contradiction it does not contain. If the source reaches a different result because the facts differ, identify that difference.

Fictional training example. One manual recommends assigning identifiers at receipt; another recommends waiting until completeness review. “But see Lena Ortiz, Small Archive Workflow 18 (2026) (recommending assignment after completeness review).” This parenthetical identifies the competing recommendation. It does not imply conflicting legal holdings or determine which workflow the office must adopt.

Use “For background, see” when the material supplies history, terminology, or broader discussion. Do not use it to hide a source that contradicts the argument. Conversely, do not describe a general historical survey as direct proof of a narrow operational claim it never addresses.

The final signal review is a source-to-sentence test. Read the proposition, read the passage, state the relationship in ordinary words, and compare that description with the displayed signal. If they differ, change the signal, the sentence, or the selected source. A correctly italicized signal is useful only when its characterization is true.