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Signals: what they mean and their order

A signal tells the reader how a source relates to your sentence. No signal means it states the point directly. See means it supports the point by inference. See also, cf. and see generally add support of other kinds, and but see points the other way. Signals run supportive, comparative, contradictory, then background, and each kind starts a new citation sentence. Italicize or underline them in memos and briefs.

Written for the 22nd edition. Updated .

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Payton v. New York, 445 U.S. 573, 586 (1980); but see Brigham City v. Stuart, 547 U.S. 398, 403 (2006).

What each signal says

No signal: the source states your point, or you are quoting it. E.g.: one of several sources that say it. See: the point follows from the source, though it isn't stated outright. See also: more support, beyond sources already cited. Cf.: the source supports an analogous point (Rule 1.2).

Compare … with: sources that are alike in an important way; the 22nd edition adds contrast … with for sources that differ in an important way. Contra, but see and but cf. point against your sentence. See generally: background reading.

Order and punctuation

Signals follow the order of Rule 1.2: supportive, then comparative, then contradictory, then background (Rule 1.3). Signals of the same kind share one citation sentence, separated by semicolons. A new kind starts a new citation sentence, so a contrary signal comes after a period: … (1980). But see …

Italicize or underline the signal in a memo or brief. Don't put a comma after a single signal (See Smith, not See, Smith), but do set off e.g. with commas: See, e.g., Smith.

  • …, 586 (1980); but see Brigham City v. Stuart, ……, 586 (1980). But see Brigham City v. Stuart, …A contrary signal starts a new citation sentence. R 1.3
  • See, Smith v. Jones, 500 F.3d 10, 12 (2d Cir. 2007).See Smith v. Jones, 500 F.3d 10, 12 (2d Cir. 2007).No comma after a single signal. R 1.2
  • See e.g. Smith v. Jones, …See, e.g., Smith v. Jones, …E.g. is set off with commas. R 1.2

What the 22nd edition changed

Explanatory parentheticals are now required after see also, cf. and see generally; the 21st edition only encouraged them. A parenthetical is also required whenever a source's relevance would otherwise be unclear (Rules 1.2 and 1.5).

Every signal except see generally now calls for a pin cite (Rule 1.2). And compare is split: compare … with for sources alike in an important way, the new contrast … with for sources that differ.

  • See also Smith v. Jones, 500 F.3d 10, 12 (2d Cir. 2007).See also Smith v. Jones, 500 F.3d 10, 12 (2d Cir. 2007) (holding that a warrant was required).22nd edition: see also takes a parenthetical. R 1.2

Questions

Are signals italicized in law review footnotes?
Yes. In citations, signals are italicized in law review footnotes as well as in memos and briefs. Only a signal used as an ordinary verb in a sentence stays roman.
Do I need a parenthetical after see?
Not as a rule. The 22nd edition requires one after see also, cf. and see generally, and after any source whose relevance isn't obvious.
What's the difference between see and no signal?
No signal means the source directly states your point or is the source of a quotation. See means the point follows from it without being stated outright.

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