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Perfect Bluebook, Automatically?

As 1Ls make progress on their open memo assignment and 2Ls/3Ls slog through cite-checking journal assignments, it seems like everyone could use a helping hand with The Bluebook: A Uniform System of Citation these days. The Goodson Law Library has some spare copies on Reserve for when you just need to confirm an abbreviation or a rule, and there is also an online version (paid subscription required) which offers full-text searching of the new 19th edition and the ability to save personal annotations for future tricky cites.

But what people really seem to want is a tool to convert citations automatically into proper Bluebook format. We’re often asked for advice on shortcuts to perfect legal citation: everything from “Can’t I just copy what it says on Lexis and Westlaw?” to “Is there a citation management software that will put footnotes together for me?” We’ve previously written about citation management tools such as EndNote and Zotero, which offer some support for Bluebook styles, but a survey of help forums will reveal frustration by users about errors in the output—perhaps unsurprising since both tools were originally designed for citation from style manuals in the sciences and the humanities, and Bluebook support came later.

CiteGenie, a Firefox add-on designed specifically for use in legal research, released a beta version this summer to favorable reviews from the legal community. The site FAQ clearly outlines what the system can and cannot do – for example, while you can copy text and references from LexisNexis, Westlaw, and WestlawNext in order to generate pinpoint citations in Bluebook format, CiteGenie cannot automatically detect subsequent cites where one would normally use the short form (e.g. “Nimmer, supra note 6”). So some user intervention and Bluebook knowledge would still be required.

LexisNexis and Westlaw citations for documents will generally give you enough information to compose a perfect Bluebook citation on your own, but as with the other tools listed here, sometimes a little editing is necessary (especially with party names and source title abbreviations). WestlawNext offers a service called “Copy with Reference” which does include Bluebook as one of its output styles. To test it, highlight the text you want to copy and paste the citation into your word-processing program. Experiments at Goodson Blogson HQ showed that the WestlawNext output was reasonably successful, although it uses the Bluepages style (for court documents and memoranda) rather than the law review style, so 2L and 3L students would need to convert a lot of underlining into italics and/or small caps. It also is unclear whether WestlawNext’s Bluebook style has been updated to reflect changes in the new 19th edition (for example, “County” was not abbreviated in one of our test cites, but it is a new abbreviation in Table 6 of the 19th edition).

In conclusion, there’s really no substitute for mastering at least the basic Bluebook citation rules on your own. Citation management software and browser add-ons can provide much-needed assistance to beginners, but only time and practice with the Bluebook would help you spot any inaccuracies or system limitations. Some popular Bluebook help guides (like Dworsky’s A User’s Guide to the Bluebook) are in the process of being updated to reflect the 19th edition changes – to find help guides and for other Bluebook queries, be sure to Ask a Librarian.

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