State v. Ruoff, 17 Fla. L. Weekly Supp. (2000). section number). Citation Form: Keeping Up with the Times - The Florida Bar In the official publication, most statutes begin with a section number and catchline followed by the text of the statute. . (d)Multiple SubdivisionsWithin a Single Section. See Bluebook R. 12 in the white pages.). See The University of Akron's Bluebook Quick Reference: Abbreviations and How-tos for help with . Those instances are usually limited to if the statute is commonly cited that way or if the information would otherwise aid in identification. endobj <> endobj See supraRule 5.7. It is updated annually and a new print edition is published every six years. Use a single section symbol with a space between the section symbol and the sections number. A chapter in theFlorida Statutesis not a session law chapter. x-x (year). Fla. Stat. 364.339 (1993),amended byAct effective July 1, 1995, ch. 1285. When the discussion concerns the present state of the law, cite to the current edition of the Florida Statutes. Not only will it increase the integrity, reliability, and persuasiveness of the instrument, but it hopefully will result in better manuscripts that ultimately will advance legal scholarship and public policy in Florida. 5 Ways to Cite Statutes - wikiHow (1995). Table of Authorities - The Ultimate Guide - Legal Office Guru (2) The official federal code is the United States Code (U.S.C. The Bluebook requires you to cite to the official code if it is available. !pCyiB(hakJ%a"J m,)Slp@[qY)p"\ 92g($,(0noclFT)/2U:8ZjMtynDJ9}22yKeK:p1bCgnX+nDk. The title, section, and text of the statute are almost always identical no matter which version you use but, to find the correct year, you will . Fla. Stat. 240.229, .2997(1) (2000). [126 0 R 127 0 R 128 0 R 129 0 R 130 0 R 131 0 R 132 0 R 133 0 R] B12(p.18): Bluepages rule for state statutes. <>stream Learn to check the Table T.1 whenever you are citing primary authority. These changes to the Manual reflect the fact that more Florida specific sources have become available online and that increasingly these online sources are certified as either official in their own right or as alternate official versions of their print counterparts. <>/Border[0 0 0]/Contents( F l o r i d a S t a t e U n i v e r s i t y L a w \n R e v i e w)/Rect[72.0 650.625 323.0938 669.375]/StructParent 1/Subtype/Link/Type/Annot>> 95-403, 27, 1995 Fla. Laws 3311, 3338-39. For example, if you wanted to reference a statute regarding the cooperation of agenciesin the National Environmental Policy Act of 1969., the proper citation would be: National Environmental Policy Act of 1969 102, 42 U.S.C. (Examples of state statutes with no formal titles. Recovery v. Progressive Am. When referring to theFlorida Statutesin footnotes or stand-alone cites of a scholarly article, use the following format: (b) Florida Statutes Annotated.TheFlorida Statutes Annotatedis the unofficial version of theFlorida Statutes. Abbreviate section references in a footnote citation sentence by using the section symbol (). Also included is the official/preferred code for that state, as well as the proper abbreviations for each code. Examples: If subsection (6) is controlling law, one election board is sufficient for this precinct. 0000001970 00000 n Number , Section number, Volume number Stat. 2d 292 (Fla. 1992). 0000002194 00000 n Bluebooking and Legal Citation: Bluebooking California Statutes 2022 by The University of Akron The University of Akron is an Equal Education and Employment Institution. For more information on how to cite supplements, please seeBluebookRule 3.1(c). x (year). <>/Border[0 0 0]/Contents()/Rect[72.0 612.5547 124.3037 625.4453]/StructParent 2/Subtype/Link/Type/Annot>> Bluebook R12.3 requires you to cite the official U.S.C. 4332 (1994). To require a report from the Secretary of Homeland Security on the Name v. Name, Volume number Reporter abbreviation Page number (Court Name). or U.S.C.S. Short Forms - Bluebook Citation - Swisher Library at Jacksonville 0000002477 00000 n 95-403, 27, at 3338-39, Laws of Fla. 364.339, Fla. Stat. Florida Mental Health Act, Fla. Stat. To find the currency ofLexis, the information for the statute can be found underneath the "Copy Citation" box but before the text of the citation itself. 0000001365 00000 n xVy~}F0N13`&p"I9:tZ"-"}]{~~x/ c HfE4sowa-n_?B. hb```e``.``a`H bg@ ~;sr~h``uf5g+'mr0)oL'Ll:3:VvO%T".>s Tgxwsk?u0u kd` R @Q@,@ZS33cqAJCuw&jU5v,)`a``l`se`Pc`Xx A- 164 0 obj 0000003735 00000 n endobj <>stream Co., 22 Fla. L. Weekly Supp. <>/Border[0 0 0]/Contents()/Rect[72.0 612.5547 124.3037 625.4453]/StructParent 2/Subtype/Link/Type/Annot>> You will also need to include the year that the statute was enacted. The United States Code is the official code for federal statutes. According to The Bluebook, you may add the name of a statute as it appears in the session law if (1) you are citing to an entire act as codified in the United States Code, (2) if the statute is commonly cited that way, or (3) if the information aids in identification of the material cited (Rule 12, p. 120, and Rule 12.3.1 (a)). (Year). State & Local Legal Research: Municipal Law - Northeastern University United States v. Lane, 474 U.S. 438 (1986). Florida Statutes should be cited as Fla. Stat. 1. Basic form Name v. Name, Volume number Reporter abbreviation Page number (Court Name). Citation Style Guides - Legal Research: Florida - UCF Research Guides 12 U.S.C.S. You wish to cite section 777.011 of Florida Statutes Annotated, published by West entirely in the 2013 main volume, for the proposition that "establishing that presence is not required for responsibility as a principal in the first degree." 159 0 obj Learn. Citing Statutes - The Bluebook - Library Guides at Nova Southeastern Federal Statutes - Bluebook Guide - Guides at Georgetown Law Library Be sure to check out the videos that explain what each part of a legal citation means. Stat. \ WKGD6=+j}<3Pns6jr-`~fY"3cmEX97$KbDS42+MQVDmQA/y24". ", "Occasional observations concerning the citation of legal authorities by lawyers and judges. endstream Rule 12.3.1 (p. 123): Rule for code citation. 0000005915 00000 n Next, click on "Constitutions and Statutes" in the left panel on the next page. Instead, use "Id." then the new section or subsection number. 996 (N.D. Texas 1997). 0000003678 00000 n In-text citation: (Family and Medical Leave Act of 1993, 2006) Most federal statutes APA citations have five basic elements: . <>/Border[0 0 0]/Contents( \n h t t p s : / / i r . When referring to theFlorida Statutesin the text of a scholarly article or in textual discussion in footnotes, theBluebookrecommends the following form in Rule 2.2: Section 95.11(3)(c) of theFlorida Statutesgoverns the statute of limitations for any action founded on the design, planning, or construction of improvements to real property. Basic Citation Forms: Florida Statutes - Florida State University 4332. (NOTE: The UCF Library provides access to many InfoTrac databases), Ask Us | UCF Homepage | UCF Libraries Homepage | Orlando, FL 32816 | Contact UCF Libraries | Report a Problem, "designed to aid practitioners and scholars in the proper use of citation form for legal documents and scholarly articles. To cite a state statute using the Bluebook, you will need the following information: the name of the state, the name of the statute, the public law number, and the chapter number. Gables Ins. According to section 102.012(6), if there are fewer than 300 registered electors one election board is sufficient. 0000014739 00000 n <>/Border[0 0 0]/Contents( \n h t t p s : / / i r . Fla. Stat. The Supreme Court has held thatmisjoinderunder Rule 8(b) is subject to harmless-error analysis (United States v. Lane, 1986). Citing State and U.S. Constitutions REFERENCE LIST ENTRY Cite the federal constitution by "U.S." or the abbreviated name of the state. Rev. 157 0 obj <>/MediaBox[0 0 612 792]/Parent 153 0 R/Resources<>/Font<>/ProcSet[/PDF/Text/ImageC]/XObject<>>>/Rotate 0/StructParents 0/Tabs/S/Type/Page>> <>/Border[0 0 0]/Contents()/Rect[493.2393 612.5547 540.0 625.4453]/StructParent 4/Subtype/Link/Type/Annot>> Name of the subject matter (if arranged by subject). 0 at 897 (e). UCF University Writing Center provides helpful handouts on grammar and punctuation, including: avoiding sexist language, bare minimum grammar, dashes & parentheses, five uncommonly serious mistakes, five easy comma rules, how to choose articles, the known-new contract, mastering prepositions, the paramedic method, passive voice Q&A, punctuation hierarchies & sentence patterns, and the semi-colon, InfoWrite (Gale Cengage Learning) Each chapter of theFlorida Statutesis further divided into sections. Material. 1846-1886:Livingston v. LEngle, 22 Fla. 427 (1886). <> Examples Start with the commonly known name of the statute. Where the id. form is used, do not include the year of the statute with the citation unless the short form citation is to a statute of a different year. 0000016238 00000 n 1997). If anything more than the section number and catchline is omitted, do not indent the paragraph for the block quotation. Access Mango via your computer or download an app to your mobile device. The Court of Appeals for the First Circuit has held that it is appropriate for a judge to refuse to direct the verdict (Flibottev. Pennsylvania Truck Lines, Inc., 1997). 328 (1991). Though each state citation form will differ slightly, all citations will generally include: T1.3 will be an indispensable source for reference, providing you with the information required for each state's statutory citation. Ohio Rev. 2d 1196 (Fla. 1985). The correct way to cite a state code varies according to the state. Basic Form Introduction. <>/Border[0 0 0]/Contents(Legal Writing and Research Commons)/Rect[137.2383 199.1906 306.7939 210.9094]/StructParent 6/Subtype/Link/Type/Annot>> When the discussion deals with the law of an earlier time, as in a discussion of an earlier court opinion construing a statute, cite to the earlier edition of theFlorida Statuteswith which the discussion deals. Follow the format found in T1.3 to cite the statute. Home. (1989). Books Example of a book: Cases l a w . Each example contains orange brackets and labels - clicking on a bracketed and labelled portion of the example will redirect to where rules concerning that element of example are included within this guide. For example, section 688.001,Florida Statutes, states: Sections 688.001-688.009 may be cited as the Uniform Trade Secrets Act. The phrase Uniform Trade Secrets Act is the name of the statute and the Act. Example: For more information on how to cite electronic media and online sources, please see Bluebook Rule 12.5. Bluebook Citation Exercise 12. Last Updated: Jun 9, 2022 11:11 AM https://nsufl.libguides.com/bluebook l a w . For information on where to find these codes online, please click here. Both state and federal statutes are published in books called codes, usually having the statutes compiled by title or subject matter. 3) rules of evidence and procedure 4) repealed statutes (cite most recently enacted first and continue towards earliest) Fla. Stat. 364.339 (1993) (amended 1995). ,d, <<5082DBC196AEB2110A0020F18B39FD7F>]/Prev 236326>> Jurisdiction is indicated. To find the currency ofWestlaw, the information for the statute can be found at the bottomof the page underneath the statute, Notes of Decisions, and Footnotes. Citing Tax Sources - Accounting & Taxation - University of South Florida Official name of act, Title No. BluebookRule 12.3.1(e) governs the way to citetosupplements and pocket parts for both federal and state statutes. 1. In the years predating 1999, they were published bi-annually following each odd-year regular session and a supplement was published following each even-year regular session. The first citation to a statute in the text of the document must be accompanied by a footnote identifying the full citation form of the statute. 931 (1966). It is important to refer to the Bluebookfor each state, as the format varies by state. House Bill 287 makes only a minor change in the vested rights provisions of chapter 380. page (date). %%EOF Name v. Name(year ) or (Name v. Name, year). Order of authorities | Wex | US Law | LII / Legal Information Institute Each time a full citation to a statute occurs, include the year. Citation to theFlorida Statutesis strongly preferred. endobj 122 0 obj This is usually done when the statute is an appropriation, has been repealed, or has its contents scattered in different parts of the Code. 162 0 obj 0000001694 00000 n Name of Act (Year) 0000002649 00000 n Give the full name of the city, town or county, followed by the abbreviation of the state (see table T1). Stat. endstream H.R. 116 (Supp. This is found in the form of a pocket part. Representative Abrams turned the focus of the debate to paragraph (1)(b). . ADA Amendments Act of 2008, Public Law 110325, 122 Stat. Ct. Feb. 13, 2010). Here is an example of a citation to a state statute using the Bluebook: Joseph Sorrentino, Plaintiff, versus Salvador A. Godinez, Defendant. Stat. 92.53(1), .54(1) (1989). Statute Citing 101 Both state and federal statutes are published in books called codes, usually having the statutes compiled by title or subject matter. BluebookRule 12.2.1 requires that you cite to the official code of each stateif available. Let us make your life just a little easier. ", "Compiled by the editors of the Columbia Law Review, the Harvard Law Review, the University of Pennsylvania Law Review, and the Yale Law Journal. It is recommended that an attorney be consulted when an interpretation of the law is needed. endobj SBC Communications, Inc. v. Federal Communications Commission, 981 F.Supp. LibGuides: Federal Legislative History: Bluebook Citations HOW TO CITE . 2d 231 (Fla. 1987). <>/Metadata 154 0 R/Outlines 123 0 R/Pages 153 0 R/StructTreeRoot 128 0 R/Type/Catalog/ViewerPreferences<>>> The Bluebook, a Uniform System of Citation, published by the Harvard Law Review, is the definitive style guide for the legal field. But if you are using the OhioSupreme Court format, (for briefs submitted to an Ohio court) the citation is: R.C. Example: 92.53(1), .54(1), Fla. Stat. 0000016421 00000 n This guide is intended to help NSU College of Law Students with legal citations, The section number of what you are citing, The year of the code volume (not the year it was enacted. (Supp. 4.1 (7 reviews) Flashcards. . About Us; Staff; Camps; Scuba. (b)Consecutive Sections. Library: APA 7 Citations: Legal and Government Documents Indent the first line of a block quotation when quoting the entire text. . 132 0 obj 115-132). Department of Transportation Act, Pub. 0000003881 00000 n 2. 35 ILCS 635/22 (West 2006). The Bluebook: A Uniform System of Citation Available at both GL and HL, Call Number: KF245.B58 2010 Introduction to Basic Legal Citation By Peter W. Martin. The Beginner's Guide to Bluebook Statute Citations Additionally, the Chicago Manual of Style recommends its use for all citation of legal material. If you are citing to a previous edition of the Code (1954 or 1939), indicate to the reader that you are doing so by including the year in parentheses after the regular citation. 168 0 obj Section 216.177 (2016) of the FloridaStatutesgoverns the form and content The general layout of a state code citation is: Abbreviated name of the code The section number of what you are citing The year of the code volume (not the year it was enacted Use the abbreviated citation form of theFlorida Statutesin the text of legal documents when the citation is intended to stand alone. A list of any available codes for each state is included in Table T1.3. Do not cite to an annotated edition unless referencing materials not present in the official codification. 0000000696 00000 n The Florida Court of Appeals held that an order for the removal of a sewer line is in the nature of an equitable order (Silverleibv.Hebshie1992). When textual discussion concerns the present state of the law, cite to the current edition of theFlorida Statutes. <>/Border[0 0 0]/Contents()/Rect[130.3037 613.5 172.1807 624.5]/StructParent 3/Subtype/Link/Type/Annot>> The editors of this Eighth Edition have updated the citation rules throughout the Manual to address advances in information technology and, consequently, online legal research. Florida Rule of Appellate Procedure 9. 0000002027 00000 n 0000003938 00000 n See Bluebook Rule 2.1. Except for citations to case reporters, all citation forms should be spelled out in full if used as an integral part of a sentence either in the text or in footnotes. The date of the code is not necessarily the same as the year the statute was published, If the information cited is found in a supplement, include the date of the supplement. For other U.S. Jurisdictions, see Table T 1.4. endobj 0000001777 00000 n 135 0 obj <>/MediaBox[0 0 612 792]/Parent 119 0 R/Resources<>/Font<>/ProcSet[/PDF/Text/ImageC]/XObject<>>>/Rotate 0/StructParents 0/Tabs/S/Type/Page>> During the debate, Representative Abrams noted that section 119.07(1)(b) had provided that when the nature or the volume of a request . A parenthetical indicating either (i) the year the source was published (for code cita-tions) or (ii) the year the statute was passed (for session laws). Homepage | The Bluebook Online Citing Florida Statutes: REFERENCE LIST ENTRY Basic Form Source Chapter (date) Examples Fla. Stat. 637 (Miami-Dade Cty. Section 90.803(23),Florida Statutes, currently provides a hearsay exception for certain statements of a child victim of abuse.85. 0000001126 00000 n Buncayo v. Dribin, 533 So. This table provides the reporter names and abbreviations, statutory compilation names and abbreviations, and citation conventions for all federal and state courts. Also, take note of the jurisdiction of the citing cases. Never use both. For example, if it's a U.S. case, go to rule 10. Handy reference for citing state statutes: Look at T1.3 for the required components of the citation as well as the proper abbreviation of the state code. endobj Numerical information that indicates the individual statute (i.e. Citing Statutes - Bluebook Guide - Guides at Georgetown Law Library Abbreviated form of the full citation: For federal statutes, you . The lessor does not select, manufacture, or supply the goods; a. 33-114(1998) (this would be the format for a brief, Bluebook Rule B12.1.2. Rule 9.800. Uniform Citation System - Rules for Florida Appellate Procedure Cummings Center for History of Psychology. The LegalEase Citations Bluebook Citation Generator is designed to make the process as simple as possible for you while producing a completely accurate statute citation - no matter how complex. <>/Border[0 0 0]/Contents(Legal Writing and Research Commons)/Rect[137.2383 199.1906 306.7939 210.9094]/StructParent 6/Subtype/Link/Type/Annot>> startxref How to Use This Manual Florida Rule of Appellate Procedure 9.800 Rule 9.800. Otherwise cite to theFlorida Statutes Annotated. 54. If the date spans multiple years, give all years covered. 134 0 obj B5 (p. 15): Sources & Authorities for statutes, rules, and regulations. 5.9.3Form of Block Quotation: Incomplete Quotation. Use the name of the state if citing to a case not decided by that state's state court. . Note:The volume and page numbers refer to U.S. Reports. U.S.C. hb```e``c`a`(Pgc@ >;sf`(A9g5gvbZrY9Ewpz:rwt44v 00zH0 aH20^@7 4T7|ga|A=QQk Below you will see examples of bluebook citations for various common authority types. Similar to federal codes, state statutes may be published in both an official code and an unofficial code. Go to the Bluebook rule for that source type. Six-Step Process To create a correct Bluebook citation, follow this quick six-step process: Figure out what type of source you want to cite: a case, a statute, a book, a journal article, etc. Bluebooking and Legal Citation: Bluebooking U.S. Statutes The preference order of the compilations are: Florida Statutes, West's Florida Statutes Annotated, and then LexisNexis Florida Statutes Annotated. Name of Act, Pub. 3553 (2008). Id. Amendment number in Roman numerals, Section number. Reporter Abbreviations Code Ann. Nothing is underlined in a statute citation. However, if parts of the statute's current version appears in both the main volume and supplement, then you must cite to both of these versions. Year (2006). Rule and Tables Rule 12 (and Rule B12 in the Bluepages) governs how to cite statutes. Use two section symbols with no space between them. Florida Style Manual Use a single section symbol with a space between the section symbol and the sections number. Gainesville, FL 32611 For laws that are not available in the official code, or when desired for clarity or adoption reference, cite in accordance withFlorida Rule of Appellate Procedure9.800. 1994),repealed bych. Citing U.S. Supreme Court Decisions REFERENCE LIST ENTRY Basic Format Name v. Name. 1.3 Acts, Laws, Bills, Treaties, Constitutions, 3.3 Legislative Bill Information Publications, 3.4 Committees, Subcommittees, and House Councils, 6.8 Parenthetical Indicating Statutory Change, 8.7 Public Employees Relations Commission Decisions, 8.8 Florida Public Service Commission Decisions, 8.10 Florida Administrative Practice Manual. This Florida Style Manual provides meaningful citation forms for Florida-specific materials. The Florida Statutes are updated annually by laws that create, amend, transfer, or repeal statutory material. Rev. Use the following template to cite an e-book or pdf using the Bluebook Law Review citation style. State statutory compilations can be found within Table T.1.3. and Special Session of the Twenty-Fourth Legislature.. 158 0 obj endobj States vary on how to cite to the code.Table 1.3 lists the official and unofficial statutory compilations for each state, in order of Bluebook preference. PDF APA-7 References to Legal Materials (Bluebook) APA 7th - Liberty University 0000014555 00000 n e d u / l r)/Rect[230.8867 220.0227 331.668 231.7414]/StructParent 5/Subtype/Link/Type/Annot>> See infraRule 5.7. 0000008622 00000 n (1993) (amended 1995). Case Law - Georgia Legal Research - LibGuides at Georgia State - GSU F., F.2d or F.3d for Federal Reporter (circuit courts) The Florida Style Manual is designed to aid practitioners and scholars to identify the proper citation form for legal documents and scholarly articles. The unofficial code citations are essentially the same as the official code citations, but adds the name of the publisher, editor, or compiler before the year. 897 (f). 1887-present: Fenelon v. State, 594 So. In the 20th edition of The Bluebook, legislative materials are found in Rule 13. 2d 737 (Fla. Dist. Use small caps formatting for the geographic area and code name. Copies of the Bluebook, 20th edition can be found on Reserve in the CSS Library. Example: 2d 935 (Fla. 3d DCA 1988). A list of any available codes for each state is included in Table T1.3. 0000000016 00000 n The Bluebook, a Uniform System of Citation, published by the Harvard Law Review, is the definitive style guide for the legal field. <>/Border[0 0 0]/Contents()/Rect[130.3037 613.5 172.1807 624.5]/StructParent 3/Subtype/Link/Type/Annot>> Name of Act Section number, Volume number U.S.C. 0000001720 00000 n 0000002706 00000 n endobj 156 20 In GovTrack.us, a database of bills in the U.S. Congress. but the title, section, . NOTE: Remember to cite the year that the code was published, not the year the statute was published. A writer should cite a state law in the APA 7th edition in the same manner. In state court proceedings, theFlorida Rules of Appellate Procedureprovide that lawyersare to "use the uniform citation system prescribed by rule 9.800" of the Rules of Appellate Procedure. EXAMPLES - CITATIONS OF . . . House Bill 287 makes only a minor change in the vested rights The published source in which the act may be found; and 3. However, each state has different rules for publishing statutes. See Table T1 in your Bluebook 21st edition for each state's rules and abbreviations.) Library Guides: The Bluebook: Citing Constitutions and Statutes The National Environmental Policy Act (1969) established the Council on Environmental Quality. 0000001308 00000 n If citing to a statute that is available on a commercial online service such as Lexis or Westlaw, provide the following: Title, Chapter, or Volume (see T. 1) Code (cite to the official code if at all possible) Section Publisher, editor or compiler Name of the database Section number. How do you cite the Florida Statutes Annotated Bluebook? <>/Border[0 0 0]/Contents( \n h t t p s : / / i r . Legal Citation Guide: Statutes - High Point University 2000). endobj F.Supp. Uniform Citation System This rule applies to all legal documents, including court opinions. Refer to an entire chapter in the same manner as a section. Advises the lessee in writing to contact the supplier for a description of any such rights. LibGuides: Citation Guides: State and U.S. Constitutions A Bill is unenacted legislation. Federal Statutes (Rule 12): A full citation to a federal statute includes three basic elements: 1. Ct. App. Sotolongo v. State, 530 So. While the legislature may create specific chapters, the legislatures Division of Statutory Revision has the final authority to determine where the legislation will be codified. 2d 514 (Fla. 2d DCA 1988). 364.339, Fla. Stat. If the current version only appears in the supplement, then the correct citation would be: 18 U.S.C. Text-Only Version. trailer Ins. ), Education and Career Center (Gale Presents Peterson's Test Prep). <>stream This name may be used in a textual discussion. For example, Connecticut's official code is theGeneral Statutes of Connecticut, and the unofficial code isConnecticut General Statutes Annotated. (c)Nonconsecutive Sections. If the statute has been amended more than once, citation to the earlier edition of theFlorida Statutesalone is sufficient. endobj The phrase should be italicized as any other textual reference to a publication. . of 1993, 29 U.S.C. 191.04, Fla. Stat. If a statute has been amended or a new statute has been enacted and it appears in either a supplement or a pocket part,BluebookRule 12.3.1(e)says that you must cite it accordingly. Chapter 380,Florida Statutes, requires that before undertaking . (Supp. See BluebookRule 5.1. Citing U.S. Supreme Court Decisions: . Ohio Rev. L. No.'), Section Number, Volume Number followed by 'Stat.' and the Page Number of the Act (Year the Statute was Passed). endobj The "long citation" (the text that actually appears in the Table of Authorities) is in quotes after the l ; the "short citation" (how you will mark a citation to that same case from this point forward) follows the s ; and the section the citation will appear in (Cases, Statutes, etc.)