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How to use id. in a citation

Id. points to the authority cited immediately before it, and only when that citation named a single source. Capitalize it to open a citation sentence and write id. inside one. Italicize or underline it, period included. Add a pin cite with at: Id. at 455. After a string cite, or once another authority comes between, use a short form instead.

Written for the 22nd edition. Updated .

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Payton v. New York, 445 U.S. 573, 586 (1980); Brown v. Bd. of Educ., 347 U.S. 483, 495 (1954). Id at 496.

What id. points to

Id. means the same source as the citation just before it (Rule 4.1). That only works when the citation before it names exactly one authority. After a string cite, id. could mean either case, so name the one you mean with a short form.

A different authority cited in between, even in a textual sentence, breaks the chain. Go back to the short form: Brown, 347 U.S. at 496.

In law review footnotes, id. can reach back to the previous footnote, but only if that footnote cites a single source.

  • Payton, 445 U.S. at 586; Brown, 347 U.S. at 495. Id. at 496.Payton, 445 U.S. at 586; Brown, 347 U.S. at 495. Brown, 347 U.S. at 496.After two sources, id. is ambiguous. R 4.1

Writing it

Open a citation sentence with Id.; anywhere else, including after a signal, it is id. The period is part of the abbreviation and takes the same italics or underlining. The at and the page that follow stay roman.

For the same page as the citation before, write Id. alone. For a different page, add it with at. For a statute, give the section instead: Id. § 1983(b).

  • Id at 455.Id. at 455.Id. always takes a period. R 4.1
  • See Id. at 455.See id. at 455.Inside a citation sentence, id. is lower case. R 4.1
  • Id., at 455.Id. at 455.No comma before at. R 4.1
  • Ibid.Id.Legal citation uses id., never ibid. R 4.1

Questions

Is id. italicized?
Yes. Italicize or underline id. together with its period; the at and page number after it stay roman. It is italic in law review footnotes too.
Can I use id. after a statute?
Yes, if the statute was the only authority in the citation before it. Give the section rather than a page: Id. § 1983(b).
Can id. refer to a case in the previous footnote?
In a law review piece, yes, as long as the previous footnote cites only that source. If it cites more than one, use the case's short form.

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