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Manual of Legal Citation/Explanatory Parentheticals
Sometimes, it is helpful to include extra information to explain the relevance of certain citations. This information goes at the end of your citation but before any citation indicating subsequent history. Explanatory parentheticals may consist of present participles, direct quotations, or short statements.
R35. General Principles for Explanatory Parentheticals
R35.1. Not quoting
- If not quoting the authority, do not begin parenthetical with capital letter.
- Example: Dr. Seuss Enters., L.P. v. Penguin Books USA, Inc., 109 F.3d 1394 (9th Cir. 1997) (holding that publisher’s parody of O.J. Simpson murder trial was substantially similar to copyrighted work).
- If quoting the authority, only begin parenthetical with capital letter and end with a period when the parenthetical quoted is or reads as a complete sentence.
- Example: See Ty, Inc. v. Publ’ns Int’l Ltd., 292 F.3d 512, 520 (7th Cir. 2002) (“[T]he shortage that creates the secondary market stampedes children into nagging their parents to buy them the latest Beanie Babies, lest they be humiliated by not possessing the Beanie Babies that their peers possess.”).
R36. Order of parentheticals
- (date) [hereinafter
<short name>] (en banc) (
<Lastname, J.>, concurring) (plurality opinion) (per curiam) (alteration in original) (emphasis added) (footnote omitted) (citations omitted) (quoting
<another source>) (internal quotation marks omitted) (citing
<another source>), http://www.example.com (explanatory parenthetical), prior or subsequent history.
- When citing directly to Internet sources, the “hereinafter” parenthetical should come right after the URL or, if one exists, the “last visited” parenthetical.