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BY DAVID J.S. ZIFF
What do you need to know about the new Bluebook? Probably nothing.
I suppose we could just end the article right here. As a practicing lawyer, you likely don’t spend much time thinking about The Bluebook. You learned whatever you needed to learn during your long-ago days as a law student, and that’s more than enough to get by today. If you’re sophisticated about your legal citations, then you think about citation more as an opportunity for persuasion, not a source of anxiety regarding improperly italicized commas.11 For more on how to use citations persuasively and even stylishly, see Alexa Z. Chew, “Stylish Legal Citation,” 71 Ark. L. Rev. 823 (2019), https://scholarship.law.unc.edu/working_papers/3/. So this year’s release of the updated 22nd edition might have sneaked up on you.
Unfortunately, Washington law requires us to pay attention to The Bluebook—at least a little bit. GR 14 states: “Citations shall conform with the format prescribed by the Reporter of Decisions” as set out in Appendix 1 of the Rule. And then Appendix 1 contains the Office of Reporter of Decisions Style Sheet, which includes as one of its “General Principles” that The Bluebook is the state’s “basic citation resource,”22 The structure of the rule is a bit confusing. GR 14 provides general citation rules, which reference the Style Sheet, but then the Style Sheet by its own terms provides rules for “Washington appellate court opinions,” which would (if taken literally) render GR 14’s citation rules otherwise inapplicable. See Style Sheet, www.courts.wa.gov/appellate_trial_courts/supreme/?fa=atc_supreme.style. as well as a lengthy list of Washington-specific exceptions to The Bluebook’s rules. We therefore need to give The Bluebook some attention. As far as I can tell, however, no published opinion has ever chastised an attorney for not adhering to GR 14’s Bluebook-related rules. So no need to go overboard.
If we’re paying attention to The Bluebook, even just a little, then we should probably know something about the updates in the 22nd edition. A caveat: This article does not provide a comprehensive list of all the updates. If that’s what you’re looking for, then please read the University of Washington Gallagher Law Library’s thorough and meticulous write-up of the 22nd edition.33 Bluebook 101: Major Changes in the 22nd Edition (last visited Aug. 21, 2025), https://lib.law.uw.edu/c.php?g=1236949&p=10950878. Here, I’m just providing some highlights (or lowlights, as the case may be) along with an analysis of the changes.
With that said, here we go:
Farewell, U.S. Supreme Court Parallel Citations
OK, so this isn’t really a Bluebook update; it’s a Washington-specific Style Sheet update. The Style Sheet requires parallel reporter citations when citing court opinions, which means Washington lawyers include the official reporter (e.g., Wn.2d) together with the regional reporter (e.g., P.3d).44 See Style Sheet R. 9. That’s why our citations look like this, Spiller v. Ware, 12 Wn. App. 34, 35, 678 P.3d 910 (2005), instead of like this, Spiller v. Ware, 12 Wn. App. 34, 35 (2005).
For citations to U.S. Supreme Court opinions, the Style Sheet went even further: It mandated not one, not two, but three sets of reporters. Until recently, Style Sheet Rule 16 required every U.S. Supreme Court citation to include information for the official United States Reports (U.S.), the Supreme Court Reporter (S. Ct.), and the United States Supreme Court Reports, Lawyers’ Edition (L. Ed.). That’s a lot of reporters!
For example, a recent opinion from the Washington Supreme Court, following the Style Sheet, included this citation: Jackson v. Virginia, 443 U.S. 307, 319, 99 S. Ct. 2781, 61 L. Ed. 2d 560 (1979).55 See State v. Roberts, No. 103546-2 (Wash. July 31, 2025), www.courts.wa.gov/opinions/pdf/1035462.pdf. A simple, standard, Bluebook-compliant citation would have looked like this: Jackson v. Virginia, 443 U.S. 307, 319 (1979). Much better.
Fortunately, we don’t have to deal with these triple reporters anymore, thanks to Professor Robert S. Chang. While a professor and the director of the Korematsu Center at Seattle University School of Law, Professor Chang filed a lot of briefs in Washington courts, and he grew tired of the wasteful reporter abbreviations cluttering up his arguments and eating into his word limits. So he did something about it: He proposed an amendment to GR 14 that eliminated the triple-reporter requirement. Public comments on the proposal were unanimously positive. And on June 5, 2025, the Washington Supreme Court adopted the change. Starting Sept. 1, 2025, the Style Sheet no longer requires three reporters for U.S. Supreme Court decisions.66 In re Proposed Amendments to GR 14—Appendix 1, Order No. 257000-A-1638 (Wash. June 5, 2025), www.courts.wa.gov/court_rule_related_orders/orders/25700-A-1638.pdf.
Review: Hooray! A simple and sensible update.
Guidance for Sources of Tribal Law
As my colleague Professor Amanda Stephen recently discussed in these pages,77 See Amanda K. Stephen, “Navigating Tribal Law Research,” Wash. St. Bar News (June 12, 2025), https://wabarnews.org/2025/06/12/navigating-tribal-law-research-a-short-guide-for-washington-attorneys/. Tribal law has been woefully undertaught in law schools. Many lawyers know little or nothing about Tribal law—how to locate it, when it’s relevant, or how it interacts with state and federal law. The Bluebook has long reflected that ignorance. The 22nd edition, however, now provides some guidance for how to cite these materials. The entirely new Rule 22 includes examples, explanations, and rules for various kinds of Tribal documents. As Professor Stephen explained, we should all know when and how to rely on sources of Tribal law. Thanks to the 22nd edition of The Bluebook, we also know how to cite them.
Review: About time!
You Can’t “Clean Up” Your Citations, But You Can “Modify” Them
OK, now we get a bit of drama. A number of years back, Washington, D.C., lawyer Jack Metzler proposed a new parenthetical citation: (cleaned up).88 Jack Metzler, “Cleaning Up Quotations,” 18 J. Appellate L. & Prac. 143 (2017). This proposed parenthetical allows lawyers to “clean up” a quotation when quoting a source that itself quotes and alters another source.
For example, pretend Case 1 (2005) says:
Cats, dogs, fish, and birds are great.
Then, later, Case 2 (2015) quotes Case 1 with modifications, like this:
Courts have explained that “[c]ats, dogs, [and] fish . . . are great.” Case 1 (2005).
Now it’s 2025 and you want to quote Case 2 for the proposition that cats, dogs, and fish are great. You don’t care about Case 1. You don’t care about birds. You just want to quote from and rely on Case 2. Under traditional Bluebook rules, you would need a (quoting Case 1) parenthetical and all those alterations. But you don’t care about Case 1. And you don’t care about how Case 2 modified the Case 1 language to make its point. That’s all too messy. You just want to quote Case 2 for what Case 2 actually says.
With the (cleaned up) parenthetical, you could do this:
“Courts have explained that cats, dogs, and fish are great.” Case 2 (2015) (cleaned up).
Notice that you are quoting Case 2 for precisely what Case 2 said. You are not indicating how Case 2 altered the language from Case 1, and for good reason: You don’t care about Case 1. The (cleaned up) parenthetical allows you to quote the source you want to quote.
This citation innovation has gained a wide following. Many courts, including the U.S. Supreme Court and the Ninth Circuit Court of Appeals, have used the parenthetical.99 See Brownback v. King, 592 U.S. 209, 215 (2021);Cruz Chable v. Garland, No. 23-3004, 2024 WL 5002373, *1 (9th Cir. Dec. 6, 2024). But see Malott v. Snyder, 261 N.E.3d 271, 272 (Ind. Ct. App. 2025) (Bailey, J., concurring) (concurring but writing separately to object to the majority’s use of the (cleaned up) parenthetical). But previous versions of The Bluebook never adopted the practice.
The 22nd edition changes all that—sort of. Rule B5.3 allows lawyers to modify quotations as described above. But the updated rule does not permit the (cleaned up) parenthetical. Instead, The Bluebook requires a (citation modified) parenthetical. A “tip” for Rule B5.3 specifically advises lawyers to avoid (cleaned up).
What gives? According to The Bluebook itself, (cleaned up) should be avoided because it “lack[s] a definite meaning in practice.”1010 The Bluebook Rule B5.3 (Bluepages Tip). That justification, however, is not the entire story. According to a recent essay by a law student who was involved with the 22nd edition’s updates, the reason was more personal.1111 M. Burke Craighead, “The Bluebook: An Insider’s Perspective,” 124 Mich. L. Rev. (forthcoming 2026), https://papers.ssrn.com/sol3/papers.cfm?abstract_id=5271305. One of The Bluebook’s student editors refused to include (cleaned up) because of a “sour interaction with Jack Metzler,” the lawyer who invented the parenthetical, and they “did not want it to seem like individual lawyers could dictate the terminology of citations to The Bluebook.” Accordingly, the editors were “willing to move forward with a similar parenthetical, but only if [the rules] used a different term.”1212 Id. at 7–8.
Seriously.
Review: Cleaning up quotations is nice, but this is too petty.
Prepare Yourself for a New Signal: Contrast
Everyone is familiar with the basic citation signals: See, Cf., E.g., and so on. You might also be familiar with the Compare signal, which allows you to compare two authorities like this: Compare Case 1 (2023) (using the “cleaned up” parenthetical), with Case 2 (2024) (asserting that the “cleaned up” parenthetical should never be used because of a personal grievance).
Well, the 22nd edition gives you a new way to compare sources with a new signal: Contrast. Previously, the Compare signal was used for situations where the sources were similar or different. But now Compare should be used for similar authorities and Contrast should be used for different authorities.
Review: Unnecessary. You can compare things by saying they are similar or different. The Contrast signal adds nothing.
You Now Can (Should?) Cite Search and AI-Generated Results
No 2025 update would be complete without something AI-related. The Bluebook is no exception. Rule 18.3 provides citation rules for outputs from large language models, search engine results, and generative AI. The citation must generally include: (1) the author of the prompt, (2) the model or service used, and (3) the exact text of the prompt submission or search query.
Perhaps you can see the problems. First, requiring the full text of a search query or AI prompt will make these citations extremely long. Queries are not always short. And AI prompts often include a series of back-and-forth questions and answers to produce a specific result. These citations are going to be monstrous.
More importantly, to the extent the citation requires inclusion of your own search queries and prompt questions, The Bluebook asks you to divulge the internal thinking and questioning processes that led you to a result. In other words, the citation will include attorney work product.
Yikes! But there is good news. First, The Bluebook doesn’t say that anyone must provide a citation for search results or AI content. Rather, the updated rules provide guidance for what to do when an author wants to cite this kind of information. As a lawyer, you could simply choose not to cite these things. Would you ever support an argument in a brief with a citation to the Lexis search query that produced the results that supported the argument? Of course not. And The Bluebook can’t make you.
Which leads me to my second bit of good news: These clunky search-related and AI-related rules are all located in The Bluebook’s Whitepages, which are specifically designed for law review students and academic authors. Those rules generally do not apply to practicing lawyers and judges. The simpler Bluepages, which are designed for legal practitioners, do not include these new rules. And while a lawyer may use the Whitepages rules to supplement the Blue-
pages, you certainly don’t have to.
Review: What a mess. Practicing lawyers and judges should not use these rules to cite their search processes.
IN CONCLUSION
So there you have it: a welcome update, thanks to Professor Chang; long overdue guidance on Tribal law; a messy personal vendetta regarding (cleaned up); an unnecessary new signal; and a rule about search engines and AI that requires you to divulge your internal thought processes. On the whole, I’d say the 22nd edition is a bit of a flop. But have no fear. You can probably just keep on using that outdated format you’ve been using for decades.
About the author
David J.S. Ziff is a teaching professor at the University of Washington School of Law. You can follow him on Bluesky at @djsziff.bsky.social.
NOTES
1. For more on how to use citations persuasively and even stylishly, see Alexa Z. Chew, “Stylish Legal Citation,” 71 Ark. L. Rev. 823 (2019), https://scholarship.law.unc.edu/working_papers/3/.
2. The structure of the rule is a bit confusing. GR 14 provides general citation rules, which reference the Style Sheet, but then the Style Sheet by its own terms provides rules for “Washington appellate court opinions,” which would (if taken literally) render GR 14’s citation rules otherwise inapplicable. See Style Sheet, www.courts.wa.gov/appellate_trial_courts/supreme/?fa=atc_supreme.style.
3. Bluebook 101: Major Changes in the 22nd Edition (last visited Aug. 21, 2025), https://lib.law.uw.edu/c.php?g=1236949&p=10950878.
4. See Style Sheet R. 9.
5. See State v. Roberts, No. 103546-2 (Wash. July 31, 2025), www.courts.wa.gov/opinions/pdf/1035462.pdf.
6. In re Proposed Amendments to GR 14—Appendix 1, Order No. 257000-A-1638 (Wash. June 5, 2025), www.courts.wa.gov/court_rule_related_orders/orders/25700-A-1638.pdf.
7. See Amanda K. Stephen, “Navigating Tribal Law Research,” Wash. St. Bar News (June 12, 2025), https://wabarnews.org/2025/06/12/navigating-tribal-law-research-a-short-guide-for-washington-attorneys/.
8. Jack Metzler, “Cleaning Up Quotations,” 18 J. Appellate L. & Prac. 143 (2017).
9. See Brownback v. King, 592 U.S. 209, 215 (2021);Cruz Chable v. Garland, No. 23-3004, 2024 WL 5002373, *1 (9th Cir. Dec. 6, 2024). But see Malott v. Snyder, 261 N.E.3d 271, 272 (Ind. Ct. App. 2025) (Bailey, J., concurring) (concurring but writing separately to object to the majority’s use of the (cleaned up) parenthetical).
10. The Bluebook Rule B5.3 (Bluepages Tip).
11. M. Burke Craighead, “The Bluebook: An Insider’s Perspective,” 124 Mich. L. Rev. (forthcoming 2026), https://papers.ssrn.com/sol3/papers.cfm?abstract_id=5271305.
12. Id. at 7–8.