Cites within Cites How do you cite to a case that is cited within another case?

Ordinarily, you should cite to the case that best supports the proposition, but you can include additional information in the citation. If a recent case cites to an older case and both cases support the proposition you are using, here are your options:

Recent Case.
Older Case.
Recent Case (citing Older Case).
Older Case (cited in Recent Case).

(If you are using a direct quotation that appears in both cases, substitute "quoting" or "quoted in" above. See ALWD Rule 46.4 for examples.)

For a closed-universe assignment (like the first memo in L.S. I, where only the materials provided with the assignment may be cited), I suggest citing only to the case that is in the assignment packet. It's not necessary to tell the reader where the proposition originally came from, as long as you cite to a case that supports it.

 

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