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![handle is hein.journals/secnd34 and id is 1 raw text is:
The Folly of the Embedded Full Citation:
How the Bluebook and ALWD manuals
Encourage Weak Legal Writing
Ben Bratman
PGLfCssor Lf Lega, W>iin
The two most prominent citation manuals for legal writing, the Bluebook and
the ALWD Guide to Legal Citation, tell us that we may place full citations to legal
authority in a separate citation sentence1 or citation clause,2 or that we may embed
them as a grammatical element of a textual sentence.' In addition, we may some-
times refer to an authority by name in the text of a sentence without a citation,
typically deferring the citation to a citation sentence that follows.4
i THE BLUEBOOK: A UNIFORM SYSTEM OF CITATION R. Bl, at 4 (Columbia L. Rev. Ass'n et
al. eds., 21st ed. 2020) [hereinafter BLUEBOOK]; ALWD GUIDE TO LEGAL CITATION R. 34.1(a),
at 294 (Ass'n of Legal Writing Dirs. & Colleen M. Barger, eds., 6th ed. 2017) [hereinafter
ALWD].
2 BLUEBOOK R. B1.1, at 4; ALWD R. 34.1(b), at 295.
' BLUEBOOK R. B10.1.1(vi), at 12; ALWD R. 34.1(c), at 295.
4 ALWD R. 34.1(d), at 295. The Bluebook does not by rule provide for textual reference to
case names with a deferred citation, but it does include examples of this practice. See, e.g.,
BLUEBOOK R. 2, at 68 (In Guth v. Loft the court held that directors also owe a duty of
loyalty to the shareholders. 5 A.2d 503, 510 (Del. 1939). . . .).](ViewImageLocal?handle=hein.journals/secnd34&div=1&collection=&method=preview&ext=.png&size=3)