{"id":1074,"date":"2020-10-16T15:37:35","date_gmt":"2020-10-16T15:37:35","guid":{"rendered":"https:\/\/citeblog.access-to-law.com\/?p=1074"},"modified":"2021-12-11T18:11:17","modified_gmt":"2021-12-11T18:11:17","slug":"bluebook-weight-reduction-program-part-two-the-merger-of-tables-t6-and-t13-2","status":"publish","type":"post","link":"https:\/\/citeblog.access-to-law.com\/?p=1074","title":{"rendered":"Bluebook Weight Loss Program \u2013 Part Two: The Merger of Tables T6 and T13.2"},"content":{"rendered":"\n<p>The twenty-first edition of <em>The Bluebook <\/em>has eliminated the separate table that previously prescribed how to abbreviate common words appearing in the name of a cited publication.&nbsp; That table, Table T13.2, was a single purpose reference, to be used solely when citing articles.&nbsp; Its columns, together with the institutional abbreviations contained in Table T13.1, turned \u201cHarvard Law Review\u201d into \u201cHarv. L. Rev.\u201d, \u201cYale Law Journal\u201d into \u201cYale L.J.\u201d, and \u201cJournal of Law, Economics, &amp; Organization\u201d into \u201cJ.L. Econ. &amp; Org.\u201d&nbsp; A writer consulted Table T6, not T13.2, when abbreviating a word in a case name or in the name of an institutional author.&nbsp; In this latest edition, <em>The Bluebook<\/em> has collapsed the two.&nbsp; The new, consolidated, T6 applies to case names, and to the names of publications, as well.&nbsp; <\/p>\n\n\n\n<h3 class=\"wp-block-heading\">Modest Gains<\/h3>\n\n\n\n<p>For the sponsoring organizations this constitutes <a href=\"https:\/\/tophat.com\/blog\/print-textbook-editions\/\">the type of periodic revision valued by all publishers of higher education texts<\/a>.  It is the sort of change that will, inevitably, undercut the market for second-hand copies of <em>The Bluebook<\/em>&#8216;s prior edition among the nation&#8217;s annual 38,000 or so beginning law students.  For users the merger achieves only a slight reduction in the book\u2019s heft\u2014two pages, plus or minus.&nbsp;Any additional gains for a novice user of the reference, one of those beginning law students, say, are less clear.&nbsp; For legal professionals committed to <em>Bluebook<\/em> compliance, as well as the research services and citation software tools upon which they rely, the change raises confounding issues.<\/p>\n\n\n\n<h3 class=\"wp-block-heading\">Significant Costs<\/h3>\n\n\n\n<h4 class=\"wp-block-heading\">Unnecessary and Confusing Case Name Abbreviations<\/h4>\n\n\n\n<p>Providing separate tables for distinct types of material poses little risk of confusion, allows them to be tailored to the word patterns characteristic of each type, and relies on an abbreviation\u2019s context to assist the reader.&nbsp; (<em>The Bluebook<\/em> continues to employ many special purpose tables\u2014one for court names, another for legislative documents, etc.)  Set against uncertain gains, the merger of T13.2 and T6 has definite costs. &nbsp;Collapsing the two deploys abbreviations that worked well so long as it was clear that they were part of a publication title into a setting in which they are far more likely to confuse.&nbsp; The word \u201cLaw,\u201d ubiquitous in journal names, illustrates the poor fit.&nbsp; \u201cLaw\u201d was never a candidate for a case name abbreviation.&nbsp; Party names contain many more, much longer, \u201cL\u201d words.&nbsp; In the new T6 &#8220;Law&#8221; has two entries and accompanying instructions on when to use each.&nbsp; \u201cJournal\u201d at seven letters was not abbreviated in prior versions of T6, but as part of a periodical name the single letter \u201cJ\u201d served as an intelligible stand-in.&nbsp; Had \u201cJournal\u201d been included in the pre-merger T6 it would most likely have been trimmed to \u201cJour.\u201d&nbsp; (The only single letter abbreviations contained in that T6 were for the four cardinal directions.&nbsp; Consistency with reporter abbreviations in Table T1 would have rendered \u201cAtlantic\u201d as \u201cA.\u201d but it is, and continues to be, shrunk only to \u201cAtl.\u201d when part of a case name,)&nbsp; Consider a 2018 decision of the Nevada Supreme Court.&nbsp; Per <em>The Bluebook<\/em>\u2019s twentieth edition, the case should be cited as: \u201c<em>Clark Cty. Sch. Dist. v. Las Vegas Review-Journal<\/em>, 429 P.3d 313 (Nev. 2018).\u201d&nbsp; Run through the new consolidated Table T6 its name becomes: \u201c<em>Clark Cty. Sch. Dist. v. Las Vegas Rev.-J.\u201d<\/em><\/p>\n\n\n\n<p>Only \u201cUniversity\u201d has been spared merged treatment.&nbsp; The T6 instructions conclude with a paragraph that applies solely to periodical titles.&nbsp; It directs that although the abbreviation for \u201cUniversity\u201d in T6 remains \u201cUniv.\u201d when that word is part of a journal name it can (and should) be reduced to \u201cU.\u201d<\/p>\n\n\n\n<h4 class=\"wp-block-heading\">The Inclusion of Abbreviations for Words that Infrequently Appear in Case Names<\/h4>\n\n\n\n<p>Any number of the words moved from Table T13 into Table T6 have fewer than eight letters.&nbsp; Many of those appear rarely, if ever, in case names.&nbsp; Examples include: Africa, Ancestry, British, Civil, Cosmetic, Digest, Dispute, English, Faculty, Forum, Human, Injury, Labor, Lawyer, Library, Military, Mineral, Modern, Patent, Policy, Privacy, Record, Referee, Statistic, Studies, Survey, Tribune, Week, and Weekly.&nbsp; Inserted into a table used to abbreviate case names, words like these constitute unnecessary clutter.&nbsp; Their prior placement in Table T13 alongside the Institutional name abbreviations with which they often must be combined (abbreviations which remain in T13) provided the writer doing a lookup or format check on a journal citation, a simpler path.&nbsp; <\/p>\n\n\n\n<h4 class=\"wp-block-heading\">Displacement of Established and Intuitive Case Name Abbreviations<\/h4>\n\n\n\n<p>The merger also forced, otherwise unnecessary, changes in a number of case name abbreviations.&nbsp; Separate tables allowed different abbreviations for the same word, with context determining which to use.  The universe of journal names is many multiples smaller than that of party names.&nbsp; In a citation they stand next to the full, unabbreviated title of the cited article and the author\u2019s name.&nbsp; This warrants a very different trade-off between the saving of space and clarity of reference.&nbsp; That is why abbreviating \u201cLaw\u201d as \u201cL.\u201d and \u201cJournal\u201d as \u201cJ.\u201d and \u201cReview\u201d as \u201cRev.\u201d\u2014in the context of a journal name\u2014works, while abbreviating a litigant named \u201cLos Vegas Review-Journal\u201d as \u201cLos Vegas Rev.-J.\u201d seems both unnecessary and cumbersome.  That is why abbreviating \u201cEmploy,\u201d \u201cEmployee,\u201d and \u201cEmployment\u201d as \u201cEmp.\u201d worked in a separate table for journal titles, but erasing the distinctions among \u201cEmployee\u201d and \u201cEmployer\u201d and \u201cEmployment,\u201d as the merged T6 does, reduces clarity.&nbsp; One can readily read and refer to \u201c<em>White v. Mass. Council of Constr. Emplrs<\/em>, 460 U.S. 204 (1983)\u201d (abbreviated according to prior editions of <em>The Bluebook<\/em>) by name, while \u201c<em>White v. Mass. Council of Constr. Emps.<\/em>, 460 U.S. 204 (1983)\u201d (abbreviated per the twenty-first edition) leaves a reader unsure, without checking, whether it is the \u201cMassachusetts Council of Construction Employers\u201d or the \u201cMassachusetts Council of Construction Employees.\u201d&nbsp; Previously, the abbreviation \u201cLab.\u201d stood for \u201cLaboratory\u201d in a case name, \u201cLabor\u201d when it appeared in a journal title.&nbsp; In context both were clear and not a source of confusion.&nbsp; The table merger forced disambiguation.&nbsp; \u201cLaboratory\u201d became a totally non-intuitive and unfamiliar \u201cLab\u2019y\u201d.   Grotesquely, under the general rules on plurals that results in an abbreviation for \u201cLaboratories\u201d of \u201cLab\u2019ys\u201d (<a href=\"https:\/\/twitter.com\/marklemley\/status\/1308564648833105920\">already, the subject of justifiable ridicule<\/a>).<\/p>\n\n\n\n<h3 class=\"wp-block-heading\">Will the Change Alter Professional Citation Practice?<\/h3>\n\n\n\n<p>To what degree will such changes in Bluebook abbreviations affect professional, as distinguished from academic, writing?&nbsp; The answer is unclear.&nbsp; It depends, in large part, on how the online research services and electronic legal citation formatting tools respond.&nbsp; <a href=\"https:\/\/citeblog.access-to-law.com\/?p=113\">Case name abbreviations remain a matter of significant jurisdictional variation<\/a>. &nbsp;For certain, the U.S. Supreme Court will continue to cite its 1983 <em>White<\/em> decision by the name \u201cWhite v. Massachusetts Council of Constr. Employers, Inc.\u201d <a href=\"https:\/\/courts.illinois.gov\/StyleManual\/SupCrt_StyleManual.pdf\">&nbsp;Illinois appellate courts citing it will not even abbreviate \u201cConstruction.\u201d<\/a><\/p>\n\n\n\n<p>In part because of this degree of jurisdictional variation, the two dominant legal data vendors offer \u201cchoice of format\u201d in their copy-with-citation features.&nbsp; Among the choices both offer for cases is one labelled \u201cstandard.\u201d&nbsp;<\/p>\n\n\n\n<div class=\"wp-block-image\"><figure class=\"aligncenter size-large\"><img loading=\"lazy\" decoding=\"async\" width=\"466\" height=\"275\" src=\"https:\/\/citeblog.access-to-law.com\/wp-content\/uploads\/2020\/10\/Case-1.jpg\" alt=\"\" class=\"wp-image-1079\" srcset=\"https:\/\/citeblog.access-to-law.com\/wp-content\/uploads\/2020\/10\/Case-1.jpg 466w, https:\/\/citeblog.access-to-law.com\/wp-content\/uploads\/2020\/10\/Case-1-300x177.jpg 300w\" sizes=\"auto, (max-width: 466px) 100vw, 466px\" \/><\/figure><\/div>\n\n\n\n<p>Currently, both LEXIS and Westlaw provide a \u201cstandard\u201d format case name for this 1985 decision of the U.S. Supreme Court at 471 U.S. 707 of:&nbsp; \u201cHillsborough Cty. v. Automated Med. Labs., Inc.\u201d&nbsp; Will they, should they convert \u201cLabs.\u201d to \u201cLab\u2019ys\u201d?&nbsp; Will they, should they retrospectively convert all the case names they deliver as part of a \u201cstandard\u201d citation to the word abbreviations brought into T6 from T13.2 or altered there because of the merger?&nbsp; When the twentieth edition of <em>The Bluebook <\/em><a href=\"https:\/\/citeblog.access-to-law.com\/?p=472\">arbitrarily altered the abbreviation for \u201cAdvertising\u201d from \u201cAdver.\u201d&nbsp; to \u201cAdvert.\u201d and the abbreviation for \u201cCounty\u201d from \u201cCnty.\u201d to \u201cCty.\u201c in 2015<\/a>, LEXIS and Westlaw followed. Bloomberg Law did not.&nbsp; \u201cAdver.\u201d still regularly appears in appellate brief citations.<\/p>\n\n\n\n<p>As  yet, none of the online research systems have incorporated the numerous new abbreviations resulting from <em>The Bluebook<\/em>\u2019s 2020 table merger.&nbsp; Will they?  May they not, instead, decide that the abbreviations resulting from this ill-considered move don\u2019t warrant the label \u201cstandard,\u201d since they fail to conform to widespread professional practice?&nbsp; An option they might consider is the addition of a new \u201claw journal\u201d format to their array of options, thereby meeting the need of those law student editors and academic writers for whom <em>Bluebook <\/em>conformity is essential.&nbsp; A similar puzzle over audience or market confronts those numerous other enterprises that provide <a href=\"https:\/\/guides.lib.uw.edu\/law\/bluebook101\/onlinetools\">legal citation formatting tools<\/a> and citation guides.<\/p>\n","protected":false},"excerpt":{"rendered":"<p>The twenty-first edition of The Bluebook has eliminated the separate table that previously prescribed how to abbreviate common words appearing in the name of a cited publication.&nbsp; That table, Table T13.2, was a single purpose reference, to be used solely when citing articles.&nbsp; Its columns, together with the institutional abbreviations contained in Table T13.1, turned [&hellip;]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[48,8,12,22],"tags":[],"class_list":["post-1074","post","type-post","status-publish","format-standard","hentry","category-abbreviations","category-bluebook","category-cases","category-journal-articles"],"aioseo_notices":[],"_links":{"self":[{"href":"https:\/\/citeblog.access-to-law.com\/index.php?rest_route=\/wp\/v2\/posts\/1074","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/citeblog.access-to-law.com\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/citeblog.access-to-law.com\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/citeblog.access-to-law.com\/index.php?rest_route=\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/citeblog.access-to-law.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=1074"}],"version-history":[{"count":20,"href":"https:\/\/citeblog.access-to-law.com\/index.php?rest_route=\/wp\/v2\/posts\/1074\/revisions"}],"predecessor-version":[{"id":1101,"href":"https:\/\/citeblog.access-to-law.com\/index.php?rest_route=\/wp\/v2\/posts\/1074\/revisions\/1101"}],"wp:attachment":[{"href":"https:\/\/citeblog.access-to-law.com\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=1074"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/citeblog.access-to-law.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=1074"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/citeblog.access-to-law.com\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=1074"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}