Adams Drafting
Citing an electronic record

Citing a multi-volume record

(Here's something I posted earlier today on Appellate Law & Practice.)

In an appellate brief, how do you cite the record? Both the Bluebook and the ALWD Citation Manual tell you to use the abbreviation "R." followed by the page number.1 That's fine — for a one-volume record. But when you have a multi-volume record, I recommend including the volume number in the citation. Bryan Garner's Redbook suggests using the volume number, the initial "R.," and the page number.2 Thus, if page 1071 appears in volume 5 of the record, the citation is 5 R. 1071.

Why include the volume number when neither the Bluebook nor the ALWD Citation Manual requires it? Because your job as briefwriter is to make it as easy as possible for the court to rule in your favor. That means making it as easy as possible for the court to find whatever you're citing. That means: don't force them to guess or figure out or hunt for the volume containing page 1071. Give them the information they need to locate page 1071 instantly.


1 Bluebook 19 (18th ed. 2005); ALWD Citation Manual 256 (3d ed. 2006).

2 Redbook 106–07 (2002).