Legal Definitions - citation sentence

A citation sentence is a distinct type of sentence in legal writing that is composed entirely of one or more references to legal authorities, such as court cases, statutes, or regulations. Its primary function is to provide direct support for the entire statement made in the sentence immediately preceding it. Unlike citations that might be embedded within another sentence, a citation sentence stands alone, always beginning with a capital letter and concluding with a period. If it includes multiple legal sources, these are separated by semicolons. It may also begin with a "signal" word or phrase, like "See" or "But see," to indicate the nature of the relationship between the preceding statement and the cited authority.

Here are some examples to illustrate how a citation sentence is used:

• Example 1: Supporting a General Legal Principle

  Imagine a legal brief states: "The principle of sovereign immunity generally protects government entities from lawsuits unless they consent to be sued."

  The citation sentence immediately following this statement would be:

  Federal Deposit Ins. Corp. v. Meyer, 510 U.S. 471, 475 (1994); United States v. Mitchell, 445 U.S. 535, 538 (1980).

  Explanation: This citation sentence consists solely of two case citations, separated by a semicolon, and ends with a period. It directly supports the broad legal principle about sovereign immunity stated in the preceding sentence by pointing to the court cases that establish or affirm this rule.

• Example 2: Citing Specific Factual Findings or Rulings

  Consider a document asserting: "The trial court found that the defendant had failed to provide adequate notice of the defect in the product, leading to the plaintiff's injury."

  The citation sentence might then appear as:

  Patel v. Global Mfg. Co., 876 F. Supp. 2d 123, 128 (D. Ariz. 2021).

  Explanation: Here, a single citation sentence provides the authoritative source (a specific court case) for the factual finding and ruling described in the preceding sentence. It begins with a capital letter, contains only the citation, and ends with a period, fulfilling all the requirements of a citation sentence.

• Example 3: Using a Signal to Indicate Related Authority

  A legal argument might state: "While the First Amendment protects freedom of speech, this protection is not absolute and does not extend to incitement to violence."

  A subsequent citation sentence could be:

  See generally Brandenburg v. Ohio, 395 U.S. 444 (1969) (establishing the "imminent lawless action" test for unprotected speech); Schenck v. United States, 249 U.S. 47 (1919) (introducing the "clear and present danger" test).

  Explanation: This example demonstrates a citation sentence that begins with a "signal" ("See generally"). This signal indicates that the cited cases provide general background or related authority for the preceding statement, rather than directly stating the exact proposition. The sentence still consists entirely of citations, separated by a semicolon, and concludes with a period.