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Source forms / F014 · Opinions

Immediate reference

Original research draft · October 2026

Working pattern

Id. at [new pinpoint].

Capture from the source

Immediately preceding source; intervening references; current locator

Check before you use it

Use only when one unmistakable source supplies the antecedent under the receiving convention.

Common error: An inserted footnote can silently change what the reference appears to mean.

Completed example

All cited sources and pagination are fictional; the immediate-reference convention is supplied for this exercise. The example illustrates dependency on context, not a universal rule for every publication.

Original uninterrupted sequence: Dawn Kiln v. Violet Ceramic, 13 TRAIN Rep. 20, 26 (Northmere Ct. App. 2025). Id. at 28.

Read the supplied source facts

Fictional packet TRAIN-O14 begins with a single-source citation: *Dawn Kiln v. Violet Ceramic*, 13 TRAIN Rep. 20, 26 (Northmere Ct. App. 2025). The next citation concerns printed page 28 of that same opinion. Nothing intervenes. For this exercise, the supplied receiving convention permits Id. when the immediately preceding citation identifies one unmistakable source. A later revision inserts a citation to the fictional TRAIN Materials Code § 8 between the two case citations. The intended supporting opinion does not change, but the immediate reference context does.

Why this works

In the original sequence, Id. points to one identifiable source, and the added page directs the reader to a different passage within it. After the code citation is inserted, the same words would appear to point to the code. The correct repair is a source-identifying case citation, such as Dawn Kiln, 13 TRAIN Rep. at 28, assuming its full antecedent remains clear under the supplied convention. Check immediate references after additions, deletions, footnote moves, and citation consolidations. Their meaning depends on surrounding text, so they can break without any character inside the reference changing.

When the facts change

If the preceding citation lists both Dawn Kiln and another source, do not rely on Id. merely because the intended opinion appears last. Use a clear short or full citation unless the receiving convention and context make the reference unmistakable. If the same page is intended, confirm whether the receiving convention permits the bare immediate reference; that formatting choice never excuses an ambiguous antecedent.

Apply the receiving court or publication’s requirements. These working forms do not establish citation permission, precedential weight, or support for a legal proposition.