Citing a multi-volume record.

In an appellate brief, how do you cite the record? Both the Bluebook and the ALWD Citation Manual tell you to use the abbreviation "R." followed by the page number.¹ That's fine — for a one-volume record. But when you have a multi-volume record, I recommend including the volume number in the citation. Bryan Garner's Redbook suggests using the volume number, the initial "R.," and the page number.² Thus, if page 1071 appears in volume 5 of the record, the citation is 5 R. 1071.

Why include the volume number when neither the Bluebook nor the ALWD Citation Manual requires it? Because your job as briefwriter is to make it as easy as possible for the court to rule in your favor. That means making it as easy as possible for the court to find whatever you're citing. That means: don't force them to guess or figure out which volume it's in. Give them the information they need to locate it instantly.

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¹ Bluebook 19 (18th ed. 2005); ALWD Citation Manual 256 (3d ed. 2006).

² Redbook 106–07 (2002).

Comments

[Salacious]

This is used by many people and is recognized by the courts. Another familiar variant would be R. 5, 1071. This, too, is recognized by many judges. Either one beats omitting the volume number.

[S. COTUS]

I use the "R. 5, 1071" method, simply because I think that putting the number first is a bit confusing, even though it is consistent with other parts of the bluebook. In some fora there might be additional variables such as page 3 of volume 5 of intervenor’s exhibit 10.

Usually people just copy someone else's format.