The Citation Code

Original research draft · October 2026

6. Explain the Source's Relationship to the Sentence

6.1 State the relationship before choosing a signal

Ask whether the source directly states the proposition, supports an inference, supplies an analogy, offers background, or conflicts with the claim. This classification should come from reading the source. Do not add a familiar introductory word merely because the sentence looks unfinished without one.

Citation Code favors direct explanations when a compact signal would hide an important qualification. “The court reached a similar result under a different statute” may communicate more than an unexplained string of authorities. The explanation belongs in the sentence or a concise parenthetical, depending on how central it is to the reasoning.

6.2 Use a small, deliberate vocabulary

The following choices describe Citation Code's working practice. A required style manual may prescribe more detailed ordering, capitalization, punctuation, or combinations.

Relationship Citation Code drafting choice
Source directly states the proposition or supplies the quoted words Place the citation directly with the proposition; no extra signal is necessary in our house practice
Source supports the stated inference Use “See” and explain the inference if it is not apparent
Source provides an analogous rule or setting Explain the analogy in words; “Cf.” alone may be too cryptic
Source provides another example Use “See also” when the additional support adds value
Source conflicts with the proposition State the conflict openly and explain its significance
Source is background rather than support Label it as background or further discussion

The point is accurate characterization. A signal cannot turn a weak analogy into direct support or make adverse authority disappear.

6.3 Write useful explanatory parentheticals

A parenthetical should tell the reader why the source is there. Identify the relevant action, reasoning, limitation, or factual comparison. Avoid a vague parenthetical such as “discussing notice” when the useful point is that the court distinguished mailing from receipt.

Fictional drafting example: “(distinguishing the date a notice was mailed from the date it was received).” This explanation names the relevant distinction. It does not claim the hypothetical case controls a different notice statute. If the distinction rests on materially different wording, say so in the analysis.

Keep quotations inside parentheticals faithful and brief. Do not patch together words from several passages without showing the edits. If the explanation needs a paragraph, move it into the text instead of burying the analysis in a long parenthesis.

6.4 Organize multiple authorities by purpose

A string citation should have an intelligible reason for its order. Group sources that perform the same job, then explain a different group if it performs another job. Follow the receiving instructions for formal ordering. Within that constraint, help the reader see the controlling authority, the additional support, and any qualifications.

Do not add a case solely to make the list look impressive. Every additional authority creates verification work and another possible mismatch. Prefer a small number of well-selected authorities to a long unexplained list. When breadth is itself the proposition—for example, that several jurisdictions take different approaches—organize the examples to show the comparison.

6.5 Recheck support after editing the sentence

A citation that supported yesterday's narrow sentence may not support today's broader one. Replacing “may” with “must,” deleting a factual qualification, or changing “some courts” to “courts” can alter the proposition without altering the citation. Review the source again when the claim changes.

Use a final support pass that reads the prose first and the source second. The question is not whether the source contains similar words. It is whether the source, in context, supports the precise proposition now being presented.