# Citation signal

In law, a citation or introductory signal is a set of phrases or words used to clarify the authority (or significance) of a legal citation as it relates to a proposition. It is used in citations to present authorities and indicate how those authorities relate to propositions in statements. Legal writers use citation signals to tell readers how the citations support (or do not support) their propositions, organizing citations in a hierarchy of importance so the reader can quickly determine the relative weight of a citation. Citation signals help a reader to discern meaning or usefulness of a reference when the reference itself provides inadequate information.
Citation signals have different meanings in different U.S. citation-style systems. The two most prominent citation manuals are The Bluebook: A Uniform System of Citation and the ALWD Citation Manual. Some state-specific style manuals also provide guidance on legal citation. The Bluebook citation system is the most comprehensive and the most widely used system by courts, law firms and law reviews.

## Use

In legal writing, citation signals appear before the citation that is being introduced. For example:
   Formatting rules for legal citations are well-defined. See generally The Bluebook: A Uniform System of Citation (Columbia L. Rev. Ass'n et al. eds., 21st ed. 2020) (describing formatting rules for legal citation and providing examples).
In the above sentence, the signal See generally is used to indicate that the source presents helpful background material related to the proposition.

## Signals indicating support
### No signal

It is acceptable to cite an authority without using an introductory signal when the cited authority (1) directly states the proposition, (2) identifies the source of a quotation, or (3) identifies an authority referred to in the text. For example:
   The United States unemployment rate fell to 4.1% in September 2024. U.S. Dep't of Lab., USDL-24-2052, The Employment Situation -- September 2024 (2024). This drop has alleviated concerns of a recession among some economists, particularly because this data comes at a time when "[r]eal-time estimates of overall economic growth remain strong." Talmon Joseph Smith, Labor Market Shows Unexpected Strength, N.Y. Times (Oct. 4, 2024).
In the above example, the author is restating numerical data from an authority and then directly quoting another authority, so no introductory signal is necessary.

### e.g.

This signal, an abbreviation of the Latin exempli gratia, means "for example". It tells the reader that the citation supports the proposition; although other authorities also support the proposition, their citation(s) may not be useful or necessary. This signal may be used in combination with other signals, preceded by an italicized comma. The comma after e.g., is not italicized when attached to another signal at the end (whether supportive or not), but is italicized when e.g. appears alone. Examples: Parties challenging state abortion laws have sharply disputed in some courts the contention that a purpose of these laws, when enacted, was to protect prenatal life. See, e.g., Abele v. Markle, 342 F. Supp. 800 (D. Conn.1972), appeal docketed, No. 72-56. Unfortunately, hiring undocumented laborers is a widespread industry practice. E.g., Transamerica Ins. Co. v. Bellefonte Ins. Co., 548 F. Supp. 1329, 1331 (E.D. Pa. 1982).

### Accord

"Accord" is used when two or more sources state or support the proposition, but the text quotes (or refers to) only one; the other sources are then introduced by "accord". Legal writers often use accord to indicate that the law of one jurisdiction is in accord with that of another jurisdiction. Examples: "[N]ervousness alone does not justify extended detention and questioning about matters not related to the stop." United States v. Chavez-Valenzuela, 268 F.3d 719,725 (9th Cir. 2001); accord United States v. Beck, 140 F.3d 1129, 1139 (8th Cir. 1998); United States v. Wood, 106 F.3d 942, 248 (10th Cir. 1997); United States v. Tapia, 912 F.2d 1367, 1370 (11th Cir. 1990). "... The term 'Fifth Amendment' in the context of our time is commonly regarded as being synonymous with the privilege against self-incrimination". Quinn v. United States, 349 U.S. 155, 163, 75 S. Ct. 668, 99 L. Ed. 964 (1955); accord In re Johnny V., 85 Cal. App. 3d 120, 149 Cal.Rptr. 180, 184, 188 (Cal. Ct. App. 1978) (holding that the statement "I'll take the fifth" was an assertion of the Fifth Amendment privilege).

### See

"See" indicates that the cited authority supports, but does not directly state, the proposition given. Used similarly to no signal, to indicate that the proposition follows from the cited authority. It may also be used to refer to a cited authority which supports the proposition. For example, before 1997 the IDEA was silent on the subject of private school reimbursement, but courts had granted such reimbursement as "appropriate" relief under principles of equity pursuant to 20 U.S.C. § 1415(i)(2)(C ). See Burlington, 471 U.S. at 370, 105 S.Ct. 1996 ("[W]e are confident that by empowering the court to grant 'appropriate' relief Congress meant to include retroactive reimbursement to parents as an available remedy in a proper case."); 20 U.S.C. § 1415(i)(2)(C ) ("In any action brought under this paragraph, the court ... shall grant such relief as the court determines is appropriate.").