ARTICLE
9 July 2026

Cite Out At The Big Nerd Corral

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Duane Morris LLP

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Duane Morris LLP, a law firm with more than 900 attorneys in offices across the United States and internationally, is asked by a broad array of clients to provide innovative solutions to today's legal and business challenges.
Two citation style guides—the California Style Manual (Yellowbook) and The Bluebook—face off in a creative showdown to help legal practitioners decide which citation format to use in California court documents. This entertaining column explores the classic debate between these competing authorities through an imaginative gunslinger-style confrontation.
United States Litigation, Mediation & Arbitration
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Here we are again for that classic showdown: Blue versus Yellow. To set the stage, recall Rule 1.200 (Format of Citations), which states: “Citations to cases and other authorities in all documents filed in the courts must be in the style established by either the California Style Manual [commonly called the Yellowbook] or The Bluebook: A Uniform System of Citation, at the option of the party filing the document. The same style must be used consistently throughout the document.” How to choose? Let’s let the guides duke it out for themselves in gunslinger style. They square off at high noon at the mesa of authorities in a small opening brief somewhere in the Golden State….

Read the full version of this month’s “Exceptionally Appealing” column from Partner Benjamin G. Shatz at the Daily Journal.

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