Although subsequent history is often appended to citations, prior history is seen less often. Prior history is stated only if it is significant to the point for which the case is being cited or if the cited decision or order does not fully describe the issues involved in the case. It is with respect to citation of cases and other materials that one should remember the system of legal citation has a grammar of its own. In the citation of a single case, the placement of commas, spaces and underlining is dictated by the grammar of the system. Similarly, one should memorize the basic rules regarding placement of commas.
Commas follow the case name and official reporter citation if there is one.
A comma also follows the parenthetical phrase if case history is provided. There is no comma after the unofficial reporter citation. Within the parenthetical phrase, there is no comma separating the court indicator and date of decision. The spacing within abbreviations of official and unofficial reporters probably causes more difficulty than other rules of the grammar of legal citation. The basic rule regarding abbreviations and spaces therein is Bluebook rule 6.1, page 47.