Citations
As amended through June 18, 2024
Notes on Citations:
Generally, citations "should be made according to the most recent edition of The Bluebook: A Uniform System of Citation," and citations to "regional reporters shall include parallel citations to official state reporters." N.C. R. App. P. at Appendix B. There are several exceptions, however. Most notably, the Supreme Court of North Carolina recently adopted a new "universal citation" method for citing to any new North Carolina case law. See below for more information. The best resource to review North Carolina's customary citation standards is The Guidebook: Citation, Style, and Usage at the Supreme Court of North Carolina, which was recently updated on 23 September 2020. The Guidebook is a 9-page PDF that has been prepared and approved by the Supreme Court of North Carolina. It was created to provide North Carolina's appellate court judges with examples and recommended instructions for formatting the citations reflected in their judicial opinions.o In its opening Foreword, The Guidebook reiterates that the appellate courts "generally follow[ ] the Uniform System of Citation that is described in The Bluebook and the style and usage conventions found in the Texas Law Review's Manual on Usage & Style." Therefore, The Guidebook is "purposefully concise" as it solely focuses on "the Court's deviations from these two reference books."
Notes on Universal Citations:
For a brief period (between 1 January 2021 to 1 February 2023), practitioners were required to cite to any new cases published by either North Carolina's Supreme Court or Court of Appeals according to North Carolina's universal citation format. However, in a 13 January 2023 Order, the Supreme Court of North Carolina rescinded this mandate, effective 1 February 2023. (See corresponding 13 January 2023 Press Release) In other words, there is no longer a need to worry about adopting a new citation format. Utilize the traditional citation method to cite to any North Carolina case law.