If the immediately preceding footnote lists more than one authority, id. should not be used in the very next footnote. In this instance, you should use supra.įootnote 20: Hannah L. Buxbaum, The Scope and Limitations of the Presumption Against Extraterritoriality, 110 AJIL UNBOUND 62, 63 (2016) see also Gevurtz, supra note 17, at 3.įootnote 21: Buxbaum, supra note 20, at 64. If the subsequent citation is to the same material but a different page than was earlier cited, simply list the new page number in the " id." citation:įootnote 17: Franklin A. Gevurtz, Building a Wall Against Private Actions for Overseas Injuries: The Impact of RJR Nabisco v. is used when citing to the source a second time, after it has already been fully cited.) (Here, the same authority is cited twice in a single footnote. Laufer-Ukeles observes that "domestic adoption involves a widely-accepted system of what is considered 'non-commercial adoption,' even including private adoption." Id. may be used.)įootnote 15: Pamela Laufer-Ukeles, Collaborative Family-Making: From Acquisition to Interconnection, 64 VILL. Footnote 2 also cites to the same case, so id. (Footnote 1 is the footnote immediately preceding Footnote 2, and cites to only one authority (a case). when citing the immediately preceding authority within the same footnote or within the immediately preceding footnote when the preceding footnote contains only one authority."įootnote 1: Johnson v. Phelan, 69 F.3d 144, 145 (7th Cir. generally.įor law review articles, "use id.
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