Legal Citations: Id., Ibid., and Supra

Some of the most confusing issues when it comes to citations revolve around the use of Id., Ibid., and Supra. When do you use them, how are they used, and is there a difference when citing via the California Style Manual and the Bluebook?

The Use of Id.

In the California Style Manual (“CSM”), Id. is used to repeat a citation to an opinion with a different point page (aka pin cite).

  • Id. is only used to refer to the immediately preceding citation in the same paragraph.
  • Id. may not be used when the citation being referred to is one of two or more in a string citation.
  • is always italicized!
  • = same opinion, but different page reference.

Example:

  • The California Supreme Court declined to characterize the plaintiff as a public figure in Khawar v. Globe International, Inc. (1998) 19 Cal.4th 254, 267 [70 Cal.Rptr. 178]. The court also declined to adopt a neutral reportage privilege in that case.  ( at p. 273.)

In this case, Id. is referencing the Khawar case but is telling the reader that the specific information referenced is on page 273.

In the Bluebook style of citation, Id. is used to refer to the immediately preceding citation in the same paragraph with no intervening authority with both: (a) the same page or section; and (b) a different page or section.  The “i” in “id” is only capitalized when it begins a citation sentence. 

The Use of Ibid.

Ibid. is only used when citing via the CSM style and is NEVER used when citing via the Bluebook style. Ibid. means “in the same place.”

When to use Ibid.:

  • To repeat an identical citation to an opinion within the same paragraph, may be used when no intervening authority is cited.
  • Identical citation (same authority, same pin cite)
  • No other authority or citation in between
  • Same paragraph
  • is always italicized!
  • = exactly the same. Nothing has changed.

Example: 

  • The conduct of the plaintiff in Khawar v. Globe International, Inc. (1998) 19 Cal.4th 254, 267 [79 Cal.Rptr. 178] did not make him a public figure. In fact, his role in the underlying controversy was “trivial at best.”  ()

In this case, the Ibid. means they are still citing the same opinion, Khawar v. Globe International, Inc., and using the same page references.

The Use of Supra

If the first subsequent reference is to a point page (aka “pin cite”) within the case opinion, either provide the first page followed by the point page, or use “at page” or “at p.” in parentheses without the inception page.

First citation:

  • (Silacci v. Abramson (1996) 45 Cal.App.4th 558 (Silacci).)

First subsequent reference:

  • (Silacci, supra, 45 Cal.App.4th 558, 562.)
  • (Silacci, supra, 45 Cal.App.4th at p. 562.)

OR

  • (Silacci v. Abramson, 45 Cal.App.4th 558.)
  • (Silacci v. Abramson, supra, 45 Cal.App.4th at p. 562.)

Example: Supra to a citation in the same paragraph.

  • Burglary is not committed by placing a stolen check in a bank’s window chute, based on the court’s decision in People v. Davis (1998) 18 Cal.4th 712, 724 (disapproving People v. Ravenscroft (1988) 198 Cal.App.3d 639.) However, burglary “may be committed by using an instrument to enter a building.” (People v. Davis, supra, at p. 717) OR (Davis, supra, at p. 717.)

The use of “supra” is to indicate that the case was previously cited in full.  You can use supra in the same paragraph when there IS intervening authority.

Example: Supra to citation in a different paragraph.

  • Based on the court’s decision in People v. Davis (1998) 18 Cal.4th 712, 724 (disapproving People v. Ravenscroft (1988) 198 Cal.App.3d 639), burglary is not committed by placing a stolen check in a bank’s window chute; burglary may, however, be committed by using an instrument to enter a building. Therefore, entering a building without permission with the use of a pocketknife is considered burglary. (People v. Davis, supra, 18 Cal.4th at p. 720.)

When in a different paragraph, include all elements of the full citation except the year and “inception” page.

When citing via Bluebook style, supra is not used for cases, statutes, or constitutions.  However, it can be used for books, reports, and internal references.

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