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Bluebook Citation: Unpublished Opinions

This guide covers an overview of Bluebook citations, FAQs, and supplemental material to aid in your legal citations.

Unpublished or Unreported Opinions

Although "unpublished" and "unreported" are used interchangeably, there is, in fact, a slight distinction between the two terms. 

An unpublished case is where:

  • The court has place a citation limitation on the opinion 
    • Typically, there is language in document that provides explicit instructions on when the case can and cannot be cited to, or a reference to a court rule that delineates that information 
  • The court has rendered the opinion not citable 
  • The court will not release the opinion to the public 

An unreported case is where:

  • A case has not been published in a hard copy reporter series 
  • The court has not place any limitations on the citation to or the publication status of the opinion, but the editors of hard copy reporters chose not to include the case

Relevant Rules & Tables in The Bluebook

  • Rule 10.8.1: how to cite to an unpublished and unreported cases 

Applicability

Unreported cases, which have not been certified for publication, are not considered a binding authority, but they can be used as persuasive authority. 

Some courts only allow citations to published cases. Thus, when preparing a document to be submitted to a court, it is good practice to check the applicable court rules to confirm whether unpublished cases can be cited to in the filings of that court. 

Effective January 1, 2021, in Illinois, an amendment to Supreme Court 23 allows for unpublished decisions to be cited to for persuasive purposes. 

Citing an Unpublished or Unreported Opinion

Elements of a Unpublished or Unreported Case Citation:

  1. Name of Case
    • Remember: If it is a court document, the case name is underlined or italicized, but if it is the first full citation of a case in a law journal article, the case is in plain text. See Rule B2 for court documents and Rule 2 for law journals.
    • Ensure that the case name is abbreviated according to Rule 10.2 
      • See Table 6 for a list of abbreviated words commonly found in case names
  2. Docket Number
  3. Database Identifier 
  4. Name of Court
    • Ensure court is abbreviated according to Rule 10.4
    • Table 1 and Table 7 provided a list of abbreviated court names
  5. Date of Decision
    • Including month (Table 12), day, and year

If a pinpoint citation is included, page numbers should be identified with an asterisk (*), and paragraph number should be identified with a paragraph symbol (¶). 

Here are a few examples:

Westlaw

Finch v. Fashion Ave. Knits, Inc., No. 01 CIV 2619 JGK HBP, 2001 WL 1550865 (S.D.N.Y. Dec. 5, 2001)

LexisNexis

Beach Forwarders, Inc. v. Serv. by Air, Inc., No. 21 C 56, 2022 U.S. Dist. LEXIS 5985 (N.D. Ill. Jan. 12, 2022)

Bloomberg Law

Hespe v. City of Chicago, No. 13 C 7998, 2016 BL 417422 (N.D. Ill. Dec. 15, 2016)

Slip Opinions

Black Law's Dictionary defines 'slip opinion' as a preliminary draft of a court opinion not yet ready for publication. Unlike unreported opinions, a slip opinion can be cited as authority. Think of a slip opinion as the decision before the reported decision. Most of the time slip opinions do not change in the substance, but they could need to fix citations or formatting. 

According to Rule 10.8.1(b), when a case is unreported but available in a separately printed slip opinion, the citation is the same as an unreported case, except the database indicator is omitted.

Elements of a Unpublished or Unreported Case Citation:

  1. Name of Case
    • Remember: If it is a court document, the case name is underlined or italicized, but if it is the first full citation of a case in a law journal article, the case is in plain text. See Rule B2 for court documents and Rule 2 for law journals.
    • Ensure that the case name is abbreviated according to Rule 10.2 
      • See Table 6 for a list of abbreviated words commonly found in case names
  2. Docket Number
  3. Name of Court
    • Ensure court is abbreviated according to Rule 10.4
    • Table 1 and Table 7 provided a list of abbreviated court names
  4. Date of Decision
    • Including month (Table 12), day, and year

Notice that the elements are the same as above, but the database identifier is omitted

Here is an example:

Agrawal v. Global Tel Link Corp., No. 1-24-0547, (Ill. App. Ct., Apr. 10, 2025)