Learning the Basics of MLA Style
The Modern Language Association (MLA) is a professional organization of scholars and teachers of language and literature. Founded in 1883, it works to strengthen the study and teaching of languages and literature. At the end of the 20th century, as newer communication technologies began to emerge, the MLA decided that it needed to develop a standard set of rules for quoting and referencing those new technologies. This resulted in the first MLA style manual, published in 1985.
When you apply MLA formatting to a source, you are primarily doing two things – giving credit to your source, and giving yourself an organization system to cite and record information. It also gives your work a more polished appearance, and helps guard against claims of plagiarism, which can arise when you don’t properly credit a source .
While there are no hard and fast MLA rules, following a general format and some specific guidelines will help you get the credit you’re looking for.
First, there are some general components you’ll want to include in your work. The most fundamental three are the author, the title of the work, and the title of the container that your work falls under.
Following the initial MLA basics, there is a general format to follow. Most academic MLA citations have two styles. The first is the Works Cited style, which compiles all of the sources at the end of your work, and the second is in-text, which offers details about the text in the body of your work within your content. In-text citations will vary in format depending on the type of source being referenced.
The Importance of Accurate Legal Citation
In the realm of legal studies, the accuracy of citation is key to maintaining the validity of arguments within research papers. The Modern Language Association (MLA) has specific guidelines that outline the correct way to cite various types of legal documents. This attention to detail not only upholds academic integrity, but also provides a reliable roadmap for readers to follow and verify the sources of information presented.
Properly attributed legal citations allow for an objective assessment of the claims made in any given research paper, and ensure that scholars are able to easily reference existing material when engaging with new legal studies. These citations are as much for the benefit of those who will come after you, as they are for you themselves, allowing for a clear and rigorous scholarly conversation across history.
General Guidelines for Citing Legal Sources in MLA Format
The basics of citing any legal text in MLA format are as follows.
Author: This is the person who composed the document. In the case of legislations, bills, and other written documents created in Congress or elsewhere, the author will be designated as "U.S. Congress". In some cases, there may be information given about the particular congress and session that created a document, particularly for older documents.
In the case of court opinions, the author will be the presiding Judge or Justices, so long as there isn’t a large panel of them, though for a Supreme Court opinion this may be layered. If the presiding judge is Henry Moore, for example, to cite his opinion you’d cite "Moore."
If two judges, two senators, etc., created the document, use "and." If more, use "et. al" instead.
Title: All titles are written in italics. That means, "Smith v. Jones." This is different that when you create a Works Cited entry for a law review article – in that case, you would not italicize the name of the case.
Titles of sessions of Congress can be confusing. For instance, HR 1234 is the name of the bill, but the works cited entry would be entitled "The 123rd Congress, 1st Session, H.R. 1234. Tax Relief Act of 2013," a technical summary of the law.
If you are referring to a working paper or similar publication, include that information, such as "Smith, Robert. "The Law of Motion." Working Paper, 23 Oct 2012.
Publication: You may need to give information about where you found a piece. As with any other literary work, this follows the author, title, publication principles.
Law Review: These follow the same "Author. Title. Publishing body, date." principles as other works, but with a caveat: if a court, Senate, or other judicial body has published a report of its activities, these are problematic.
Proceedings: Proceedings may be abbreviated. "U.S. House of Representatives, 2010, 111th Congress. Proceedings of the House of Representatives" may be shortened to "2010. 111th Congress. House Proceedings."
As always, when using MLA as a citation style, refer to the actual MLA Handbook when compiling your citations, as the rules are constantly updating and changing, and several exceptions or special requirements may apply to the work in question.
How to Cite American Federal Laws
A cite to the U.S. Code has a standard format as shown:
27 U.S.C. § 841 (2018) (codification).
27 U.S.C. refers to the Title of the U.S. Code. In this case it was Title 27. U.S.C. is the abbreviation for United States Code. § is the abbreviation for section and 841 is the section number. (2018) is the year of the edition of the code used. The date is always more recent than the legislation being cited.
Suppose you are citing the Controlled Substances Act enacted in 1970 and codified in the U.S. Code. Your cite goes in this order:
27 U.S.C. §§ 301-99 (1970).
It is important not to use a date later than the date of the statute you are citing to. The court will assume the code publisher used the date that corresponds with that specific code edition.
All citations to statutory material in the MLA Handbook are in sequence and completely spelled out according to the order shown above. Pay close attention to capitalization and italics as these must be exact.
For future reference, here are the abbreviation rules for codes:
Title: Abbreviate only if the title number is greater than one. If the title is one, do not abbreviate.
Code: Abbreviate to the first letter of the code term, the period indicator, and the abbreviation for United States Code.
Section: Abbreviate to § for the first section referred to and §§ for two or more sections.
Section Symbol: Use the appropriate section symbol (§) for text citations. Use the word "section" when it is not in a parentheses citation.
If there are no statutory codes, use court decisions, administrative decisions, tribunal decisions, or other decisions interpreting the statute.
Additional information about citing laws with examples may be found in the MLA Handbook Chapter 29.
Citing State Legislation in MLA Style
State statutes are a little different than federal laws and codes. State codes use title numbers instead of title and section numbers—and as always, the MLA Handbook recommends that you follow a style manual when available. The MLA, however , avoids the use of citation abbreviations; here is how you would cite state laws:
Idaho Code
Idaho Code Ann. § 18-4501 (Michie 2011).
Maine Rev. Stat. Ann. tit. 21-A, § 50 (West 2012).
Minnesota Stat. § 97A.425 (2010).
Neb. Rev. Stat. Ann. § 21-6803 (LexisNexis 2005 & Supp. 2012).
Referencing Legal Cases
Should you find the need to reference a case in this section, it should be included in the following format:
Name v. Party, Volume Abbreviation Page (Court Year)
Should you need to reference more than one party in the case, it should be included in the format of x vs. y.
Docket number information is not needed, as the case can be identified by both the parties’ names and the court issuing the decision.
Abbreviations will be need to be used for applicable portions of the citation, so here is a breakdown of a few common ones:
Abbreviation
Meaning
Ct.
Court
Cir.
Circuit
U.S.
United States
N.J.
New Jersey
App.
Appellate
F.
Federal
Sup.
Superior
Ch.
Chancery
Dep’t
Department
For example, here is an example of how this would look if I was including a New Jersey Appellate Division case in my works cited:
Smith v. Jones, 345 N.J. Super. 456 (App. Div. 2009)
Here is how this would look if I was using MLA for a New York Supreme Court case, which isn’t a supreme court in the federal level term, but is instead the trial level court for New York State.
Smith v. Jones, 23 Misc. 3d 858 (N.Y. Sup. Ct. 2009)
This will probably be the most commonly referenced source for your legal essay, as these cases are more readily available than court rules and statutes. Make sure that when referencing a case you do not reference a court rule or a state statute, as these have their own designated format for citing.
Avoiding Common Citation Mistakes
A common pitfall for high school students and university writers is citing cases. When you write a report, journal article or even a general paper, you often use case law to back up your argument or to expand upon the legal concepts introduced in your paper. If you’re using case law, you already know that citing it can be complicated. However, it becomes even more so if you’re using a citation style other than the Bluebook—like MLA. Many students and legal authors turn to the Legal Citation Styles (part of our series of style guides for those of you who need more than just basic help finding sources) publication to also help them with these citations. Be careful not to use the other manuals in conjunction with this one!
So how can you as a writer or a student avoid these common pitfalls? Well, simply looking at the way the source is cited can eliminate any confusion. For instance, if you want to cite a case, you want to follow the MLA format for a court case: The Year v. The Year. But the thing is, the case is actually written The Applicant v. The Applicant, so many students don’t realize that they also need to cite the case’s name as it appears. For example:
Baker v. Smith, 123 U.S. 456 (1986)
But the actual case name is:
Applicant v. Smith
Common Mistake: ‘Applicant’ and ‘Smith’ are italicized in the citation. The actual case name is printed in regular type. This doesn’t seem like a huge problem, so it’s not a common mistake but it is worth it to double-check and make sure when you see the case name in general, you are taking it from the actual case citation.
Now, let’s take a look at something that is typically a common mistake – quoting from a case. When you quote from a case, you want to focus on the fact that you are quoting from a specific page: The Year v. The Year, pg number(s) So many students will forget to add the page number(s). This is easy to do because when you are writing your paper and adding in the citations, you are focusing on the subject matter of your paper not so much your citations.
Common Mistake: ‘124’ and ‘125’ are italicized in the citation – the year and page number should always be italicized. However, the case name itself, Applicant v. Smith, should never be italicized.
Also, when you quote from a case, you want to make sure that you are using the reporter from the publication you’re describing. Students often will use the reporter from cases that are listed in Westlaw and/or publishers other than Westlaw. You can get the reporter information you need from the Legal Citation Styles manual so that you won’t run into any confusion.
Common Mistake: ‘131’ should be italicized – 131 is the reporter. ‘U.S.’ should never be italicized. The page number should never be in Roman numerals.
So much paperwork has been saved by simply knowing how to use MLA correctly.
Using MLA Citations Tools
The use of MLA citation tools can significantly streamline the process of creating citations for legal documents. Legal professionals no longer have to manually sift through sources to find the necessary citation information. Many tools are specialized for legal sources through integration with legal research applications such as Casetext, Westlaw, or Fastcase. Some of the most popular MLA citation tools include:
Zotero, a free and open-source tool, helps in automatically generating MLA citations as well as APA, Chicago, and other citation styles. Users can input their legal sources into Zotero, which will then suggest the correct format of the citation for the respective legal style. Zotero also allows easy importing of information by adding a browser extension.
Easybib by Chegg is free with the option to upgrade to a premium version. This tool can generate citations across more than 15 writing styles. Like Zotero, users can install a browser extension to help them grab citation information directly from the web. The tool allows users to type the legal source information, or they can upload it to generate a citation for them .
Mendeley is a reference manager and academic social network. While it is targeted towards students and researchers, it does support MLA citations under its paid premium version. Mendeley helps users read, manage, annotate papers, and especially for this purpose, generate citations. It also has a robust desktop version to help users take citations offline.
Cite This For Me is a free online tool by Chegg that allows users to create citations in several different formatting styles including MLA. Users can copy their source URL or ISBN to have the tool fetch the relevant information. They can use the tool online or add a browser extension to avoid switching back and forth between windows.
BibMe is a free MLA citation generator for web pages and books. It does not require account registration and is entirely based in a web browser. Users can choose to enter the information manually, or can provide a book’s ISBN to have the tool fetch the relevant data automatically.
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