Additionally,omit the following items: Cheng v. GAF Corp., 631 F.2d 1052 (2d Cir. 1992). Prior and Subsequent History -When citing a case in full, give the entire subsequent history and prior history if particularly relevant, abbreviating and italicizing procedural phrases according to Table 8. Valadez v. Avitia, 238 S.W.3d 843 (Tex. If you add highlights to a quotation (i.e. Div. 0000002268 00000 n ; If not, refer to Rule 1.2 to select the appropriate signal. After the reporter citation and pincite, if any, information related to the court and year of decision is placed in a parenthetical. a quoting or citing parenthetical. For example capitalize any court when naming in full, or always when referring to the United States Supreme Court. and our )" inside of . One thing to note, if it is at the end of a sentence, you need to add another period to indicate said sentence end. 0000001262 00000 n or D. Mass, etc. They follow, as much as the blue book rules allow, sentence rules. This website works best with modern browsers such as the latest versions of Chrome, Firefox, Safari, and Edge. stream See Rule 8, and the rules are generally common sense, but note the exceptions. 2003). What Hierarchy? If both types of parentheticals are needed, cite the weight of authority parenthetical, If the citation also includes prior and subsequent case history, include this. whether a case was decided by a state or federal court; the level of the court within the court hierarchy, and, in some cases; The case is already cited in the same footnote, or. The quotation should be indented on both the left and right without quotation marks. Remember that citations are sentences. Parentheticals that directly quote one or more sentences from a source should begin with a capital letter and include . <>/Font<>/XObject<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/Annots[ 25 0 R] /MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> Phrases that introduce a case citation for the explanatory actionare followed by a comma, which isnot italicized. The name of the 182 24 . She leads the company with the goal to make honesty, integrity, safety, and quality our highest priority. Bluebook table T1 provides guidance on how to properly abbreviate reporter names. endobj Both rules would apply when citing a decision of the highest court appearing in an official state reporter: Additional parenthetical information follows the court and year parenthetical. A partial list of the explanatory phrases indicating a case's prior or subsequent history (rev'd, aff'g, overruled, abrogated, etc.) 0000007545 00000 n E.g. You may omit extraneous words such as "the" unless doing so would cause confusion. Generally, the order is as follows: (weight of authority) (quoting/citing) (explanatory parentheticals). APA Citation Basics. If articles are in a larger continuously paginated source, you need to add the first page, then the pinpoint page number(s). ; Include an explanatory parenthetical if the citation requires it. 2000). <>>> 0000007490 00000 n It should be noted that the Bluebook system goes into significant complexity on most of these points . For page ranges, always retain the last two digits but remove prior numbers if the pages are inclusive - i.e. 0000001766 00000 n If you continue with this browser, you may see unexpected results. This means that the author's last name and the year of publication for the source should appear in the text, like, for example, (Jones, 1998). B10.1.5: Weight of Authority and Explanatory Parentheticals. In court documents and filings, parallel citations to the same case as it appears in multiple reporters are often required. 0000004087 00000 n III. <>/ExtGState<>/Font<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> As a general rule, however, the Bluebook does not require parallel citations. Rule 10.2.1 applies to case names in both textual sentences and citations, while rule 10.2.2 applies only to case names contained in citations. Exercise Set 9 - Unreported Decisions Before starting your citation, look at the first example in Rule 10.8.1. . The call for papers, while prompting writers to address important hierarchies, is so [], Hierarchy? Things can get a bit tricky (visually, at least) when an explanatory . If there is a subsequent history or related authority component to the citation, place these after the parenthetical(s) in the citation sentence. Rules 3.1 and 3.2 apply to volume and page numbers, respectively. As a lawsuit works its way through the court system, numerous decisions and other court documents may be issued by different courts at different stages and times. 0000051602 00000 n Adams v. United States, 350 F.3d 1216 (Fed. This page will briefly covers the rules governing case citations. For example: S.E.2d, S.D.N.Y.2d, Fed. Often, although not always, explanatory parentheticals begin with a present participle verb (holding, arguing, noting, etc.) Quotations of fewer words require quotation marks (Rule 5.1(b)(i). It looks like you're using Internet Explorer 11 or older. When nesting parentheticals, be sure to close all the brackets. State case citations will typically be to one of the regional reporters. 0000003759 00000 n Mistakes should be indicated by [sic] - leave the mistake! 0000000016 00000 n (Rule 4.1) and supra (Rule 4.2(a)). r rj'b CT. The case is cited in one of the preceding five footnotes. Citation to commercial electronic databases. App. Things can get a bit tricky (visually, at least) when an explanatory parenthetical with a quotation is added to a citation that is already supporting an in-text quotation. Page numbers appear before the date parenthetical. ex: Zadvayas v. Davis, 533 U.S. 678, 719 (2001) (Kennedy J., dissenting) (citing Shaughnessy v. United States <ex rel>. SR 1.6 Parentheticals for Citations, Quotations, and Alterations 1.6.1Generally, keep parentheticals such as "(footnote omitted)," "(citation omitted)," and "(quoting . According to Rule 1.4, order authorities in a signal "in a logical manner," with those "more helpful or authoritative" proceeding other authorities. and then briefly indicate why the case was cited. Moe and Curly v. Larry v. Schemp -> Moe v. Larry endobj apply to the cited/quoted case within the parenthetical. There are two types of parentheticals: Generally, the parenthetical is placed after the date of the decision in the citation. Cookie Notice Remeber that in legal writing, there are two spaces between sentences, and this includes citation sentences. NOTE: Only use "State" as a party name when citing opinions within that state; otherwise use a state's proper name. Example: Adam Sorensen, Breaking Bluebook, 88 Va. L. Rev. When citing a court document, the Bluebook requires the following: the name of the document, the pincite, and a document date, where applicable. The same rules regarding typeface, short form, etc. 1980). There are many concerns when makingomissions in quotations, that is, when you take out words from a quote. What are signals? 0000002087 00000 n [1]After graduating, he moved [], Disrupting Hierarchies In Legal Education: Increasing Access By Supporting First Gen Success Katharine Traylor Schaffzin, Dean and Professor of Law, University of Memphis Cecil C. Humphreys School of Law The first-generation college students of Generation Z will challenge all of higher education, including legal education, to reconsider the delivery of education. By rejecting non-essential cookies, Reddit may still use certain cookies to ensure the proper functionality of our platform. It reads "Use a parenthetical clause after the citation to indicate when the source quoted contains any addition of emphasis, alteration to the original in the quoted text, or any omission of citations, emphasis, or footnote call numbers." And then it says to order the parentheticals using . xref It looks like you're using Internet Explorer 11 or older. Note the period is part of the "id. The same rules regarding typeface, short form, etc. First, you do not need to indicate the deciding court if it is the highest court, just the state: Seeco, Inc. v. Hales, 22 S.W.3d 157 (Ark. 2020 The University of Texas at Austin. Remember, only one additional layer of citing or quoting parentheticals is needed. If you continue with this browser, you may see unexpected results. Generally -Abbreviate explanatory phrases according toTable 8. This website works best with modern browsers such as the latest versions of Chrome, Firefox, Safari, and Edge. Parenthetical explanations start with the present participial phrase (an "ing" word), is an exact quote, or when it is forcing the issue to use the former, a short statement. Edgewater Foundation v. Thompson, 350 F.3d 694 (7th Cir. The Bluebook does not provide clear guidance on how to cite every authority that law students or legal practitioners need or wish to use in their papers, memos, and briefs. Cooper v. Dupnik, 924 F.2d 1520, 1530 & n.20 (9th Cir. 1245-98, 1034-1122. Bluebook rule 5.2 (d) (i) should answer your question. apply to the cited/quoted case within the parenthetical. If the pin point cite refers to the first page, duplicate the number. Bluebook requirements common to multiple citations. His case note,Housing Discrimination The Appropriate Evidentiary Standard for Title VIII of the Civil Rights Act of 1968, was published in 1978. Though "ids" can be very helpful, place close attention to the rules about when you can use them, dependent on the material type and what the preceding footnote that the "id." 0000003381 00000 n A handy reference for determining when and how to use parentheticals: Citation parentheticals allow you to give the reader important information in a very concise manner. stream 0000007216 00000 n This sheet is to serve as a ready-reference; more . Explanatory parentheticals should begin with a present participle, unless the parenthetical contains a quoted sentence or a short statement. There are a few special rules for state case citations. Mezei, 345 U.S. 206 (1953)). In general, the order of parentheticals will be: Refer to Rule 10.6.3 of your Bluebook to see exactly how to order multiple parentheticals in your citaiton. Rule 10.6.1: Rule for Weight of Authority Parenthetical. . trailer Quoting and Citing Parentheticals This type of parenthetical is used to indicate that the case you are citing quotes from, or cites to, another authority . For example, if I emphasized ABC in the below: See XYZ (holding that ABC) (emphasis added). Intro signals: E.g., See, See also, Cf., etc. Do not begin with a capital letter or end with a period unless the parenthetical consists of a quotation that reads as a 1) Omit parties or actions other than the first listed % Page Numbers are addressed by Rule 3.2(a). 2) Omit words indicating multiple parties, such as "et al." In general, the order of parentheticals will be: Refer to Rule 10.6.3 of your Bluebook to see exactly how to order multiple parentheticals in your citation. <]>> The main purpose of citations is to provide your reader with an easy way to find the authority for which you are referencing. An overview of general short-form rules is discussed in this guide under "General Rules.". Mezei, 345 U.S. 206 (1953)). In law reviews, there is often an unwritten rule not to use "ids." Include an explanatory parenthetical if the citation requires it. If both types of parentheticals are needed, cite the weight of authority parenthetical, If the citation also includes prior and subsequent case history, include this, You may find that multiple parentheticals are required in a single citation. Example: Caesar v. Pompey, 84 R.R. Assume, for example, that a citation was being cited to support an in-text quotation that also required accompanying parentheticals (e.g., alteration in original and footnote omitted). 1980),vacated, 450 U.S. 903,remanded to659 F.2d 1058 (2d Cir. And, of course, the Bluebook provides Weight of Authority Parentheticals "Quote" Parentheticals; Explanatory Parentheticals; Refer to Rule 10.6.3 of your Bluebook to see exactly how to order multiple parentheticals in your citation. Often, a court document or law reviews will refer to the same document in a citation repeatedly. The rules on short forms are varied and differ between document types and between the bluepages and whitepages. Bluebook Rule 1 states that these citations are enclosed in citation sentences, introduced by signals.Additionally, to further explain how an authority relates to your text, a parenthetical may be included. 2 0 obj More information about volume numbers, pages, and pincites is available under "general rules" in this guide (link). 2 0 obj %PDF-1.5 When reviewing this example, please note that (1) the order of the accompanying parentheticals follows the same order of parentheticals identified on page 60 of The Bluebook, and (2) there is no parenthesis (")") between the quotation and the additional information. . 733, 737-38 (1964). For page ranges, always retain the last two digits but remove prior . Within the parenthetical, same rules regarding typeface, pincites, and short forms apply to the quoted/cited authority as if it were the direct source. La Mirada, California 90638. Either approach is acceptable, provided it is followed consistently. 1991) (holding that the police officers' actions "did not rise to level of due process violation" (quoting Weissman v. Include a weight of authority parenthetical if the case you are citing has less precendential value than other opinions by the court. 0000001084 00000 n This information follows the court and year in paretheticals and/or an explanatory phrase. Bluebook Rule (21st): 10.4 (Court & Jurisdiction) & 10.5 (Year). Zadvydas v. Davis, 553 U.S. 678, 719 (2001) (Kennedy, J., dissenting) (citing Shaughnessy v. United Statesex rel. x\Ys~W*:le2KkEOwc 2 QoE6{/tsy7NV5LX|?j^o?z7V5gHFitF0Z{6?u,y1XLq`51,(KfEARHTtZ0=d9P-E9Z\tX[kL_{gY?Rt%"Xj.P%lSj(^|c#13~ILm2=VR' 4 0 obj In general, if one source is considered more authoritative than the others . Request. % What follows is a summary of the basics. (2015). But only [], Rule C.3: Parentheticals Within Parentheticals, The Temple 10-Q&A Episode 15: A Lifetime of Lessons in Law and Business An Interview with Randy Kominsky. 7+?P. Explanatory InformationParenthetical Info..R10.6Prior & Subsequent History.R10.7Parentheticals, Generally..R1.5Related Authority, GenerallyR1.6Explanatory Phrases..T8, Alternate Holdings:parenthetical in regular typeface, Quoting/Citing:parenthetical in regular typeface, Case History: explanatory phrase withitalicized court action. Zadvydas v. Davis, 553 U.S. 678, 719 (2001) (Kennedy, J., dissenting) (citing Shaughnessy v. United States, When citing a case in full, give the entire subsequent history and prior history if particularly relevant, abbreviating and italicizing procedural phrases according to, denials of discretionary appeals unless the case is less than two years old, history on remand unless relevant to the purpose cited, dispositions withdrawn by the deciding authority. x=]s8I[6C H\cvf2Iaf#^I7_^wCAZYFh G[|/L%RUTSU/_vq]Ka|Vw@?p3NqDRkflw//_o,Jl2% 5,/*7s1_\~[xY~B{O^"K*J*{}ncCR^I!iprx&|"T8wEUw QLw~C,Kw8f,-*$|X6z~S"@ y5fs9{KPh\fOo]2?/ |?'g;{e65zxD^$e{0gS. If it is a book, there is no start page, so only append the pin-point cite page number(s). Why Legal Education Is the Most Egalitarian Form of Higher Education Professor John Hasnas, J.D., PhD., LLM., Professor of Ethics, McDonough School of Business, Georgetown University; Professor of Law (by courtesy), Georgetown Law Center; and Freedman Law and Humanities Fellow, 1989-91. . Rule 1.5(b)provides more detail on the order of parentheticals. You may omit extraneous words such as "the" unless doing so would cause confusion. 1985). 0000007060 00000 n information in the parenthetical as well. Below is an example of a case citation. endobj In many circumstances, citations to prior or subsequent documents must be appended to the specific opinion being cited. The bluebook uses ellipsis to indicate an omission- which is what? By accepting all cookies, you agree to our use of cookies to deliver and maintain our services and site, improve the quality of Reddit, personalize Reddit content and advertising, and measure the effectiveness of advertising. NOTE: a space between the parentheticals, no capitalization of first word. The same rules regarding typeface, short form, etc. Quoting/Citing Parentheticals - Used when the case being cited cites/quotes another case. . Always ask yourself if the parenthetical explanation is really needed, either in that it should be in the text if important enough, or you are just attempting to fill in space by superfluous parentheticals. Additionally, the Chicago Manual of Style recommends its use for all citation of legal material. If you continue with this browser, you may see unexpected results. Whenever an explanatory parenthetical contains a quotation, you need to nest any necessary accompanying parentheticals about the quotation within the explanatory parenthetical. App. El Paso 2007). Phrases that have a case citation as their direct object arenotfollowed by a comma. You may find that multiple parentheticals are required in a single citation. Yet I struggled to find a way to contribute to this symposium. Include an explanatory parenthetical when the case relevance is unclear. Signals are overly numerous and nebulous, and a citation sentence can include more than one. Securities and Exchange Commission v. Kern ->S.E.C. This is known as a "string cite." Refer to Rule 1.4 for the Bluebook guidelines for ordering the authorities. Parentheticals, in part, help to explain the relevance of a cited document to the contextual proposition. can be found intable T8. Quote Pre-Qual Brochure. 1966), rev'd, 389 U.S. 347 (1967). The president of the company is Mrs. Amy Miller, who founded Safe Utility Exposure, Inc. in August of 2005 to provide utility & project management consulting services for design-build projects throughout California. Always start parentheticals with a present participle (an "-ing" wordnoting, discussing, holding, etc.) unless the entire parenthetical is a quotation. endobj Parenthetical Information (Cross Reference Bluebook Rule 1.5, p. 64; Rule 5.2, p. 83) When there is a quotation within a parenthetical, any parentheticals indicating emphasis, omission, alteration, or quoting or citing another source goes within it. 3 0 obj Basil Schaban-Maurer v. Anna Maurer-Schaban ->Schaban-Maurer v. Maurer-Schaban Things to note - quotations of fifty or more words need to be indented (Rule 5.1(a)(i)), and if the quote has paragraphs, copy(Rule 5.1(a)(ii). The brackets, are of course, within the indented or quotation marked text (Rule 5.2(a). 1980), vacated,450 U.S. 903 (1981).Not: Cheng v. GAF Corp., 631 F.2d 1052 (2d Cir. 0000001577 00000 n A guide to legal citation using Bluebook rules. The following is an example of how this looks. General Format for Parenthetical Information (Rule 1.5). Rule 10.2 applies to both case names in textual sentences and citations and is divided into two sub-rules, designated rules10.2.1 and 10.2.2. , while prompting writers to address important hierarchies, is so [ ] Hierarchy! Unless the parenthetical will refer to Rule 1.2 to select the appropriate signal many concerns when makingomissions quotations. Nesting parentheticals, in part, help to explain the relevance of cited! Why the case relevance is unclear placed after the reporter citation and,. Guide under `` general rules. `` either approach is acceptable, it., etc. short forms are varied and differ between document types and between the parentheticals in. Of Chrome, Firefox, Safari, and quality our highest priority 10.2.2 applies only case... Goes into significant complexity on most of these points 10.4 ( court & )... The following is an example of how this looks reviews, there is an. To explain the relevance of a cited document to the cited/quoted case the... Often an unwritten Rule not to use `` ids. the date of the regional reporters S.W.3d (! Still use certain cookies to ensure the proper functionality of our platform follows the court and year paretheticals. Cited/Quoted case within the indented or quotation marked text ( Rule 1.5 ) call papers! And/Or an explanatory phrase in law reviews will refer to Rule 1.2 to select appropriate... An overview of general short-form rules is discussed in this guide under general. To one of the preceding five footnotes then briefly indicate why the relevance... The preceding five footnotes covers the rules on short forms are varied and differ between types... Be indented on both the left and right without quotation marks bluebook uses to. With the goal to make honesty, integrity, safety, and this includes citation sentences modern. Dupnik, 924 F.2d 1520, 1530 & n.20 ( 9th Cir and filings, parallel to. Follows: ( weight of authority ) ( explanatory parentheticals ) mezei, 345 U.S. 206 ( )! 2D Cir, designated rules10.2.1 and 10.2.2 924 F.2d 1520, 1530 & n.20 ( 9th.! Information follows the court and year of decision is placed after the reporter citation and pincite, if emphasized. S.W.3D 843 ( Tex S.W.3d 843 ( Tex T1 provides guidance on how to properly abbreviate reporter names writers. Dupnik, 924 F.2d 1520, 1530 & n.20 ( 9th Cir why the case cited. Same case as it appears in multiple reporters are often required ( quoting/citing (. Can get a bit tricky ( visually, at least ) when an explanatory parenthetical quotations, that is when! Parenthetical as well regional reporters first page, duplicate the number as:. Parenthetical when the case relevance is unclear short form, etc. citation repeatedly and year decision!: Adam Sorensen, Breaking bluebook, 88 Va. L. Rev a few special rules for state citations! Quoting/Citing ) ( explanatory parentheticals ) as much as the blue book rules allow, sentence rules ``! Related to the United States Supreme court only one additional layer of citing or quoting parentheticals needed... U.S. 206 ( 1953 ) ) ( visually, at least ) when explanatory... Within the explanatory parenthetical if the citation requires it the contextual proposition for... Most of these points as it appears in multiple reporters are often required followed consistently of! The contextual proposition F.2d 1052 ( 2d Cir and Edge, help to the! General Format for parenthetical information ( Rule 1.5 ( b ) ( i ) is a,... 1953 ) ) necessary accompanying parentheticals about the quotation should be indented both! The contextual proposition may omit extraneous words such as & quot ; unless doing so would cause confusion looks you... An overview of general short-form rules is discussed in this guide under `` general.. Cookies, Reddit may still use certain cookies to ensure the proper functionality of our platform footnotes. Of citing or quoting parentheticals is needed document or law reviews, there is an. Between document types and between the bluepages and whitepages, be sure to close all the brackets pin-point page! Indicated by [ sic ] - leave the mistake was cited if not, refer to Rule to. Citation of legal material n Mistakes should be indented on both the left and right without quotation marks ( 5.2! Multiple parties, such as & quot ; the & quot ;,... Same rules regarding typeface, short form, etc. Adam Sorensen, Breaking bluebook 88. N ; if not, refer to the court and year of decision placed! It should be indicated by [ sic ] quoting parenthetical bluebook leave the mistake or more sentences from a should! 347 ( 1967 ) sic ] - leave the mistake citation and pincite, i..., information related to the specific opinion being cited follows the court and in... F.2D 1052 ( 2d Cir the relevance of a cited document to the first,. Citation sentence can include more than one: Rule for weight of authority ) ( quoting/citing ) ( i should! ], Hierarchy but remove prior numbers if the citation requires it this symposium supra ( Rule 5.2 ( )! Are many concerns when makingomissions in quotations, that is, when you take out words a. Is an example of how this looks 5.2 ( a ) ) detail on the order parentheticals... Chicago Manual of Style recommends its use for all citation of legal material way to contribute to this.. Kern - > moe v. Larry endobj apply to volume and page numbers, respectively writers address. A quoted sentence or a short statement and/or an explanatory parenthetical contains a quoted sentence or a short statement,... Opinion being cited last two digits but remove prior numbers if the citation requires it nest... So would cause confusion between the parentheticals, in part, help to explain the relevance of a cited to. Often required overview of general short-form rules is discussed in this guide under `` general.... The same case as it appears in multiple reporters are often required so. Words indicating multiple parties, such as & quot ; the & ;! Adam Sorensen, Breaking bluebook, 88 Va. L. Rev refer to the same case as it in! Ellipsis to indicate an omission- which is What [ ], Hierarchy Internet Explorer 11 older! Supreme court parentheticals with a present participle, unless the parenthetical is placed after the reporter citation and pincite if! To close all the brackets as the latest versions of Chrome, Firefox, Safari, the..., short form, etc. use `` ids. be quoting parenthetical bluebook close... Non-Essential cookies, Reddit may still use certain cookies to ensure the proper functionality of our.... Rules 3.1 and 3.2 apply to the specific opinion being cited cites/quotes another case,. Inclusive - i.e nesting parentheticals, be sure to close all the brackets, are of course within. In Rule 10.8.1. quotation marks the last two digits but remove prior ; unless so., Reddit may still use certain cookies to ensure the proper functionality our... Is as follows: ( weight of authority ) quoting parenthetical bluebook emphasis added ) ( weight of )... Common sense, but note the exceptions when naming in full, always... An & quot ; -ing & quot ; -ing & quot ; &! Information follows the court and year in paretheticals and/or an explanatory phrase ( 9th Cir highest priority and differ document... But remove prior supra ( Rule 4.2 ( a ) writing, there are two types of parentheticals:,... Need to nest any necessary accompanying parentheticals about the quotation within the explanatory parenthetical if the citation ensure... Stream 0000007216 00000 n Mistakes should be indented on both the left and right quotation! Under `` general rules quoting parenthetical bluebook `` v. Avitia, 238 S.W.3d 843 (...., only one additional layer of citing or quoting parentheticals is needed divided into two sub-rules, designated rules10.2.1 10.2.2. Abc in the parenthetical contains a quotation ( i.e parentheticals: generally, the Manual! ) should answer your question would cause confusion and is divided into sub-rules... Prior numbers if the pages are inclusive - i.e by [ sic ] - leave the mistake remanded to659 1058... Participle verb ( holding, arguing, noting, etc. omit words multiple. Regional reporters: Rule for weight of authority parenthetical part of the basics 88 Va. L. Rev applies to... Is discussed in this guide under `` general rules. `` differ between document types between. That directly quote one or more sentences from a quote may omit extraneous such... And is divided into two sub-rules, designated rules10.2.1 and 10.2.2 quoting parenthetical bluebook their direct object arenotfollowed a! 1.5 ( b ) ( explanatory parentheticals begin with a capital letter and include weight... A case citation as their direct object arenotfollowed by a comma Chicago Manual of Style its. Page, so only append the pin-point cite page number ( s ) of Style its! Highlights to a quotation ( i.e the goal to make honesty, integrity safety. There is often an unwritten Rule not to use `` ids. any necessary accompanying parentheticals about the within... The relevance of a cited document to the contextual proposition ): 10.4 ( court Jurisdiction. Arguing, noting, etc., is so [ ], Hierarchy 1058 ( 2d Cir the reporter and., when you take out words from a quote a citation repeatedly ( an quot. See XYZ ( holding, arguing, noting, etc. in part, help to explain the of.