More child’s play
Irony of the day

Citing a multi-volume appellate record

This is a topic I’ve written about before, but I think it bears repeating.

We all know that, when referring to the record (or the appendix, or the transcript), we must give a page citation. For instance:

  • R. 123.
  • App. 456.
  • Tr. 789.

I recommend that if the record (or appendix or transcript) is multi-volume, include the volume number too — even if the pages are numbered consecutively from one volume to the next. As with citing the case books or a multi-volume treatise, put the volume number before the abbreviation and the page number after.1 Thus:

  • 1 R. 123.
  • 2 App. 456.
  • 4 Tr. 789.

Neither the Bluebook2 nor the ALWD Citation Manual3 mentions giving the volume number, but I think you should give it anyway. Why? Let’s say you refer your reader to transcript page 3478. If your citation is “Tr. 3478,” you force the reader to figure out which volume contains page 3478. The result: A minute or so of the reader’s time that otherwise would have been spent thinking about your argument will instead be spent searching that voluminous record for the volume containing that page.  Give the poor reader the volume number, and you’ll maximize the time the reader spends thinking about your argument.

Remember, the purpose of a citation is not just to comply with court rules, or to give the bare minimum information needed to find the supporting material. The purpose is to enable the reader to find the supporting material instantly. So if you refer the reader to anything that comprises more than one volume, always give the volume number — even when the pages are consecutively numbered from one volume to the next.

Some people cite a multi-volume record by giving the abbreviation, followed by the volume and page numbers separated by a colon. Thus:

  • R. 1:123.
  • App. 2:456.
  • Tr. 4:789.

The problem with this solution is that it may cause confusion. Generally in a citation, a colon is used between the page number and the line number.4 If you use a colon to separate volume number from page number, you may throw off readers who expect a colon to separate page number from line number.

We cite the law books by volume number, abbreviation, and page number. For example: Younger v. Harris is 401 U.S. 37; it’s not U.S. 401:37. Use the same volume-abbreviation-page convention to cite any multi-volume source, including the appellate record.

1 See Bryan A. Garner, The Redbook § 8.5 (2002).
2 The Bluebook, Practitioner’s Note P.7 and § 10.8.3 (17th ed.).
3 Darby Dickerson, The ALWD Citation Manual § 29.5 (3d ed.)
4 See The ALWD Citation Manual § 29.5(b); The Redbook § 8.5(b).


Darby Dickerson

The ALWD Citation Manual actually does mention the issues of volume numbers with regard to transcripts. Specifically, Rule 29.3(b) provides an example of a citation to a multi-volume transcript.

Ray Ward

Thanks, Darby, I’d missed that.

In case anyone doesn't have their ALWD Citation Manual handy, the example Darby refers to looks like this:
“Tr. Transcr. vol. 2, 47–49 (Mar. 21, 2006).”

This follows the ALWD convention of citing any multi-volume source, e.g. treatises. ALWD puts the volume number after the title of the work and denotes it with the abbreviation “vol.”

Ben Shatz

Citing to the record volume is not just a good idea, but is specifically required by rule in California appeals. See Cal. R. Ct. 8.204(a)(1)(C).

T. Little Piggie

I agree with your advice on record cites, and, in fact, many people do use the 32 R. 435 form. I also agree that R. 32:435 may be misleading. I tend to use another variation (out of habit, mostly), which is R. 32, 435.


Ancient comment but, you never cite to the line, do you?

Ray Ward

MNPundit: Citing to the line is rare, but sometimes appropriate. Of course, you need to be citing a page with line numbers printed in the left margin. If the cited page has no line numbers, then citing to the line is useless.

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