Employing proper citation form is a primary way to demonstrate that you’re a careful and astute appellate practitioner. As we discussed here, for decades the preferred citation style in California appellate courts has been found in the California Style Manual, colloquially referred to as the “Yellow Book.” We therefore read with interest this proposal by the Orange County Bar Association to amend the Rules of Court and the Government Code to require that all documents filed in California courts, and all California appellate opinions, “be in the style established by The Bluebook: A Uniform System of Citation.”
The reason given for the proposed change is: “Most lawyers work hard in law school to master the citation forms set forth in The Bluebook, which has long been the traditional legal citation guide throughout the country. But California puts out its own citation guide: the California Style Manual. California courts are required to follow the California Style Manual by the Reporter of Decisions, who acts under authority of the California Supreme Court and Government Code section 68902. Lawyers in this state are therefore encouraged—and lawyers for the state are required—to abandon their hard-won Bluebook expertise and learn a confusing new citation system.”
We think it is a useful exercise to re-assess existing practices from time-to-time to determine whether they should be changed. That said, based on the reactions we have heard thus far, this proposal does not appear to be gaining traction among appellate practitioners. By and large, they do not seem to find the Yellow Book confusing and many think its citation form superior to that of The Bluebook. Therefore, absent a more persuasive reason than has been articulated, we would be surprised to see a major departure from the system presently followed by tens of thousands of California judges and lawyers. Indeed, the difficulty and expense of retooling courts’, firms’ and publishers’ forms and macros would, in itself, be a substantial impediment to abandoning the Yellow Book.
