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'Id.' and 'ibid.' are two of the most frequently used Latin abbreviations in legal writing, mainly used in footnotes and endnotes to refer back to previously cited sources.
These terms save space and reduce repetition when multiple references are made to the same source. They are used to avoid restating the full citation when the same source is cited consecutively.
When used correctly, 'id.' and 'ibid.' make citations easy to follow and also ensure that the flow of legal content remains uninterrupted by repetitive source information. In this article, I explain how to use them correctly.
What are 'Id.' and 'Ibid.'?
'Id.' is a shorthand for the Latin word 'idem,' which translates to 'the same.'
In legal writing, 'id.' is used to refer to the immediately preceding citation, particularly when the same source is cited consecutively but might include a different pinpoint (such as a page or section number). For instance, if the same case or book is being cited again with a different page number, 'id.' can be used to avoid repeating the entire citation.
'Ibid.' is short for 'ibidem,' which means 'in the same place.' This term is used when the exact same source and pinpoint as the immediately preceding citation are being referenced.
👉Unlike 'id.,' which can accommodate different pinpoint references, 'ibid.' strictly refers to the same source and pinpoint. It is used when multiple consecutive references are identical.
Is there a difference between id. & ibid.?
Id.
'Id.' is used when a writer needs to cite the same source consecutively but may require a different pinpoint citation. For example, if you first cite a book and later need to refer to another page of the same book in the next footnote, you would use 'id.' with the specific page number.
Ibid.
'Ibid.' is used when the citation immediately repeats the previous one exactly, including the pinpoint citation. It is suitable only when the subsequent citation references the identical page or section as the one before. 'Ibid.' helps maintain a concise flow when multiple consecutive citations are identical, keeping the footnotes neat and avoiding redundancy.
Examples:
Using 'Id.'
Footnote 1: John Doe, Legal Writing Essentials 45 (2023).
Footnote 2: Id. at 47.
In this example, 'id.' is used because the source remains the same, but the pinpoint citation changes from page 45 to 47.
Using 'Ibid.'
Footnote 1: Jane Smith, Understanding Legal Citations 22 (2022).
Footnote 2: Ibid.
Here, 'ibid.' is used because the second citation refers to the exact same source and page number as Footnote 1.
Correct Placement and Punctuation of 'Id.' and 'Ibid.'
Placement in Citations:
'Id.' and 'ibid.' should appear directly in footnotes or endnotes, immediately following the citation they reference.
Footnotes: These terms are typically placed at the beginning of a footnote, immediately followed by any necessary pinpoint information (e.g., page numbers).
Endnotes: If endnotes are used instead of footnotes, "id." and "ibid." function identically but are positioned according to the note's sequence.
Punctuation Rules:
The correct punctuation and capitalization of 'id.' and 'ibid.' are critical to maintaining consistency and professionalism in legal writing.
Period Placement: Both 'id.' and 'ibid.' always end with a period because they are abbreviations of Latin words.
Capitalization: These terms are usually lowercase unless they appear at the beginning of a sentence or footnote.
Comma Use: If a pinpoint citation (e.g., page number) follows 'id.' or 'ibid.,' a comma is generally not required between the term and the pinpoint. However, this depends on the style guide being followed.
Specific Style Guide Rules:
Bluebook Guidelines:
Bluebook specifies that 'id.' can be used with pinpoint citations to indicate different pages or sections of the same source, while 'ibid.' is reserved for repeating the exact same citation.
'Id.' should not be italicized and should be lowercase unless it starts a citation sentence.
Bluebook generally prefers 'id.' over 'ibid.' due to clarity, though both are acceptable when correctly used.
ALWD Citation Style Preferences:
ALWD treats 'id.' similarly to Bluebook, allowing for pinpoint variations.
The ALWD manual de-emphasizes the use of 'ibid.' in favor of 'id.' to reduce confusion.
Common Errors and How to Avoid Them
Misuse of 'Ibid.' in Non-Immediate Citations:
'Ibid.' should only be used when referencing the immediately preceding citation without any changes to the pinpoint location. A common error occurs when writers use 'ibid.' even if a different citation has intervened.
Incorrect Usage of 'Id.' with Different Sources:
'Id.' is specifically for the previously cited source and using it when referencing a different source is a common mistake.
There can also be errors in forgetting to place a period after the terms or related to the placement of a comma. Make sure that these terms are capitalized only when starting a footnote, not in the middle of a sentence.
Maintain Consistency:
Establish a consistent approach by adhering strictly to one citation style throughout your document. Avoid switching between 'id.' and 'ibid.' unless required by the guidelines of the specific style you are using. Double-check each citation sequence to ensure you are using the correct term in the correct context.
Using Citation Management Tools:
Citation management tools like Zotero, EndNote, and legal-specific tools like LexisNexis and Westlaw provide structured citation templates that automatically format citations according to the Bluebook or ALWD guidelines. These tools reduce the manual errors often associated with frequent and complex citation adjustments.
What to do when id./ibid. cannot be used?
If id. and ibid. cannot be used due to an intervening reference, you can refer to the previous source using "supra" or by repeating the full citation. Depending on the style guide, you can choose one these options:
Using "Supra": If you need to refer back to a source that was cited earlier but not immediately before, you use "supra" followed by a specific reference to the earlier citation. For example:
Previous Citation:
12. John Doe, The Evolution of Legal Theory (2024), at 45.
Subsequent Reference:
14. Supra note 12, at 55.
Repeating the Citation: In some cases, it's clearer to repeat the full citation, especially if the intervening reference is lengthy or complex. This ensures that readers can easily locate the referenced source without ambiguity.
Using a Shortened Form: If the source was cited recently and the context is clear, you might be allowed to use a shortened form of the citation in some style guides:
Shortened Form:
Doe, Legal Theory, 55.
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