
The practice of writing out numbers in footnotes of law review articles is a nuanced aspect of legal writing that reflects both stylistic conventions and clarity considerations. While many legal writing guides, such as the Bluebook, recommend spelling out numbers below ten in text and using numerals for those ten and above, footnotes often follow different rules. In law review articles, footnotes typically adhere to a more consistent use of numerals for all numbers, regardless of size, to maintain precision and avoid ambiguity. This approach ensures uniformity and aligns with the technical nature of legal citations and references. However, exceptions may arise depending on the specific journal’s style guide or the author’s discretion, highlighting the importance of consistency within individual articles. Understanding these conventions is crucial for legal scholars and practitioners to produce polished and professional work.
| Characteristics | Values |
|---|---|
| Common Practice | Numbers are typically written out in words in footnotes of law review articles for numbers below 100. |
| Exception for Technical Data | Numbers representing technical data, statistics, or precise measurements are often written in numerals, even in footnotes. |
| Consistency | Consistency is key; if a number is written out in words in the text, it should also be written out in words in the corresponding footnote. |
| Ordinal Numbers | Ordinal numbers (e.g., first, second, third) are generally written out in words in footnotes. |
| Page Numbers | Page numbers in citations are always written in numerals, even in footnotes. |
| Dates | Dates are typically written in numerals in footnotes, following the format "month day, year" (e.g., June 15, 2023). |
| Style Guide Adherence | Law review articles often follow specific style guides (e.g., Bluebook, ALWD) that dictate number usage in footnotes. |
| Clarity and Readability | The primary goal is to ensure clarity and readability, so numbers should be presented in a way that is easily understandable to the reader. |
| Recent Trend | There is a growing trend toward using numerals for numbers above 10 in footnotes, especially in more modern or digitally focused law reviews. |
| Institution-Specific Rules | Some law schools or journals may have their own specific rules regarding number usage in footnotes, which should be followed accordingly. |
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What You'll Learn
- Citation Style Guidelines: APA, Bluebook, or Chicago Which style mandates written-out numbers in footnotes
- Number Threshold Rules: When to write out numbers (e.g., one to ten) in footnotes
- Consistency in Footnotes: Ensuring uniformity in number presentation across all article footnotes
- Exceptions for Technical Data: Rules for numbers in statistical or legal data footnotes
- Editorial Preferences: How law review editors influence number formatting in footnotes

Citation Style Guidelines: APA, Bluebook, or Chicago? Which style mandates written-out numbers in footnotes?
When determining which citation style mandates written-out numbers in footnotes, particularly in the context of law review articles, it is essential to compare the guidelines of APA, Bluebook, and Chicago styles. Each of these styles has distinct rules regarding the use of numbers in footnotes, and understanding these differences is crucial for accurate and consistent citation practices.
APA Style (American Psychological Association) generally requires numbers 10 and below to be written out in text, while numbers above 10 are expressed in numerals. However, APA style is less commonly used in law review articles, which typically favor Bluebook or Chicago. In APA footnotes, the same rule applies: numbers 10 and below should be written out, while higher numbers are presented in numeral form. This guideline is consistent across both text and footnotes, making APA relatively straightforward in this regard.
Bluebook Style, the predominant citation style in legal writing, has specific rules for numbers in footnotes. According to the Bluebook, numbers below 100 should generally be written out in text, but in footnotes, all numbers (regardless of size) are typically expressed in numerals. This distinction is important for law review articles, as footnotes are a critical component of legal citation. For example, if citing a case or statute in a footnote, the number would appear as a numeral, even if it is below 100. This rule ensures clarity and consistency in legal citations.
Chicago Style (also known as CMOS, Chicago Manual of Style) offers flexibility in its treatment of numbers. In general text, Chicago recommends writing out numbers zero through one hundred, rounded numbers, and any number beginning a sentence. However, in footnotes, Chicago style often follows a similar approach to Bluebook, where numerals are used for all numbers, regardless of size. This is particularly true in disciplines like history or law, where Chicago may be adapted to align with Bluebook conventions for footnotes.
In summary, when considering which citation style mandates written-out numbers in footnotes, the answer varies. APA style requires numbers 10 and below to be written out in both text and footnotes. Bluebook style, the standard for law review articles, generally uses numerals for all numbers in footnotes, regardless of size. Chicago style typically uses numerals for numbers in footnotes, though it may allow for written-out numbers in specific contexts. For law review articles, Bluebook is the most relevant style, and its preference for numerals in footnotes aligns with the precision and clarity required in legal citations. Understanding these nuances ensures adherence to the appropriate citation style guidelines.
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Number Threshold Rules: When to write out numbers (e.g., one to ten) in footnotes
In legal writing, particularly in law review articles, the presentation of numbers in footnotes is governed by specific style guides, such as The Bluebook: A Uniform System of Citation or individual journal guidelines. One common rule pertains to the number threshold, which dictates when numbers should be written out in words (e.g., "one" to "ten") versus when they should appear as numerals (e.g., "1" to "10"). This rule is rooted in readability and consistency, ensuring that footnotes remain clear and professional. Generally, numbers one through ten are written out in words when they appear in footnotes, while numbers 11 and above are expressed as numerals. This threshold rule is widely accepted in legal writing and helps maintain uniformity across law review articles.
The rationale behind the number threshold rule is twofold. First, writing out numbers one through ten in words aligns with traditional grammatical conventions, which emphasize clarity and flow in sentences. Second, it avoids the visual clutter that can arise from using numerals for small numbers, especially in footnotes where space is often limited. For example, a footnote referencing "5 cases" is more readable than "5 cases," and it blends seamlessly into the text. However, this rule is not absolute and may be subject to exceptions based on the context or specific journal requirements.
It is important to note that the number threshold rule applies primarily to non-technical or non-statistical numbers in footnotes. When numbers are part of a citation, statistical data, or a specific legal reference (e.g., "Rule 11"), they are typically expressed as numerals regardless of their value. For instance, a footnote citing "42 U.S.C. § 1983" would retain the numeral "42" even though it falls below the threshold. This distinction ensures that technical or legal references remain precise and recognizable.
Another consideration is consistency within the document. If a law review article adopts a specific style guide, such as The Bluebook, the number threshold rule should be applied uniformly across all footnotes. Inconsistencies, such as writing "seven" in one footnote and "7" in another, can detract from the article's professionalism. Authors should also consult the guidelines of the specific law review journal they are submitting to, as some journals may have their own variations on this rule.
Finally, while the number threshold rule is a standard convention, authors should exercise judgment in its application. For example, if a footnote contains a series of numbers that includes both single-digit and double-digit values (e.g., "two, 15, and nine"), it may be preferable to express all numbers as numerals (e.g., "2, 15, and 9") for consistency. Similarly, if a number begins a sentence in a footnote, it should always be written out in words (e.g., "One hundred cases were reviewed") to adhere to grammatical rules. By carefully applying the number threshold rule, authors can ensure that their footnotes are both compliant with legal writing standards and accessible to readers.
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Consistency in Footnotes: Ensuring uniformity in number presentation across all article footnotes
Consistency in footnote presentation is a critical aspect of legal writing, particularly in law review articles, where precision and uniformity are paramount. When it comes to numbers in footnotes, authors must adhere to a consistent style to maintain professionalism and readability. The question of whether numbers should be written out or expressed in numerals within footnotes is a common consideration. While there is no universal rule, establishing a clear and consistent approach is essential for any legal publication.
In law review articles, the general practice is to follow established style guides, such as The Bluebook: A Uniform System of Citation, which is widely used in the legal field. According to The Bluebook, numbers below 100 should typically be spelled out in text and footnotes, while numbers 100 and above are expressed in numerals. For example, a footnote would read, "There were ninety-nine cases cited in the brief" for numbers below 100, and "The court referenced 250 similar rulings" for numbers 100 and above. This rule ensures a neat and consistent appearance throughout the article. However, there are exceptions to this guideline, such as when a sentence begins with a number, in which case the number should always be spelled out, regardless of its value.
Maintaining consistency in number presentation is crucial for several reasons. Firstly, it enhances the overall readability of the article. Inconsistent formatting can be jarring for readers, making it difficult to focus on the content. A uniform style allows readers to easily scan through footnotes, quickly identifying relevant information. Secondly, consistency demonstrates attention to detail and adherence to legal writing standards. Law review articles are often subject to rigorous editing and peer review, and a consistent footnote style reflects well on the author's professionalism.
To ensure uniformity, authors should establish a clear set of guidelines for their article. This includes deciding on a specific style guide to follow and then applying it rigorously. For instance, if an author chooses to use The Bluebook, they must be diligent in spelling out numbers below 100 and using numerals for larger numbers in every footnote. Additionally, authors should be mindful of exceptions and special cases, such as percentages, decimals, and numbers appearing at the beginning of a sentence, which may have their own unique formatting rules.
In the editing process, authors and editors should pay close attention to footnotes, checking for any deviations from the chosen style. This includes verifying that numbers are presented consistently and that any exceptions are correctly applied. A thorough review will ensure that the final article meets the high standards expected in legal scholarship. By prioritizing consistency in footnote number presentation, law review articles can achieve a polished and professional appearance, contributing to the overall quality of legal writing.
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Exceptions for Technical Data: Rules for numbers in statistical or legal data footnotes
In legal writing, particularly within law review articles, the general rule is to spell out numbers below ten and use numerals for ten and above. However, this rule is not absolute, especially when dealing with technical data such as statistical or legal data in footnotes. Exceptions for Technical Data arise because precision and clarity are paramount in these contexts. When footnotes contain statistical data, legal citations, or other technical information, numerals are typically used regardless of the number’s value. For example, if a footnote references a specific statute, such as "42 U.S.C. § 1983," or a statistical finding like "7 out of 10 respondents," numerals are preferred to ensure accuracy and readability. This exception aligns with the Bluebook and other legal citation guides, which prioritize consistency and clarity in technical references.
Another critical aspect of Exceptions for Technical Data involves the presentation of numerical ranges or series in footnotes. When footnotes include ranges such as "5–10 cases" or series like "2, 4, 6, and 8," numerals are always used, even if the numbers fall below ten. This rule prevents confusion and maintains uniformity, especially in complex legal or statistical analyses. For instance, a footnote discussing a legal trend over "3–5 years" would be clearer with numerals than with spelled-out numbers. Similarly, when referencing percentages, fractions, or decimals in technical data, numerals are mandatory, as in "25% of cases" or "3.5 million dollars," to avoid ambiguity and ensure professional presentation.
Legal citations in footnotes also fall under Exceptions for Technical Data, as they often involve specific numerical identifiers. For example, case citations like *Brown v. Board of Education, 347 U.S. 483 (1954)*, or statutory references such as "Cal. Penal Code § 459" rely on numerals for accuracy. These citations are governed by strict formatting rules, and deviating from the use of numerals could lead to errors or misinterpretation. Similarly, when referencing legislative histories, court rules, or administrative codes, numerals are essential to maintain the integrity of the legal reference. This exception underscores the importance of adhering to established legal writing conventions in technical contexts.
In statistical data footnotes, the use of numerals extends to tables, charts, and graphs embedded within or referenced by the footnote. For example, if a footnote directs the reader to "Table 2," which contains numerical data, consistency demands that all numbers within the table—regardless of their value—be presented as numerals. This practice ensures that the data is easily scannable and comparable. Additionally, when footnotes include calculations or mathematical expressions, such as "the mean was 8.5," numerals are used to preserve the technical nature of the information. This approach aligns with the broader goal of legal writing: to communicate complex information clearly and efficiently.
Finally, it is important to note that Exceptions for Technical Data in footnotes are not limited to statistical or legal citations but also apply to dates, page numbers, and other specific identifiers. For instance, a footnote referencing a document on "page 12" or a historical event occurring in "1964" would use numerals for clarity and consistency. These exceptions reflect the nuanced nature of legal writing, where the rules governing numbers are adapted to serve the needs of the content. By adhering to these exceptions, authors ensure that technical data in footnotes remains precise, professional, and accessible to readers, thereby enhancing the overall quality of law review articles.
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Editorial Preferences: How law review editors influence number formatting in footnotes
Law review editors play a pivotal role in shaping the stylistic and structural consistency of legal scholarship, including the formatting of numbers in footnotes. While there is no universal rule governing whether numbers should be written out in words or expressed numerically in footnotes, editorial preferences often dictate the approach. Many law reviews adhere to established style guides, such as *The Bluebook: A Uniform System of Citation* or the *ALWD Citation Manual*, which provide general guidelines. However, editors frequently exercise discretion to ensure uniformity within their publication. For instance, some journals may require numbers below ten to be written out (e.g., "five") while using numerals for ten and above (e.g., "15"). This decision is often rooted in readability and aesthetic considerations, as well as the journal’s historical practices.
Editorial preferences regarding number formatting are also influenced by the type of content within the footnote. For example, in footnotes that contain primarily textual explanations or legal analysis, editors may favor writing out numbers to maintain a formal tone. Conversely, in footnotes heavy with statistical data, citations, or page numbers, numerals are often preferred for clarity and conciseness. Editors must balance these factors while ensuring consistency across the entire publication. This often involves creating internal style guides that supplement or clarify broader citation manuals, providing authors with clear directives on number formatting.
The influence of law review editors extends beyond mere adherence to rules; it reflects their commitment to enhancing the readability and professionalism of legal scholarship. Editors may prioritize stylistic coherence over rigid adherence to external guidelines, especially when dealing with ambiguous cases. For instance, they might choose to write out numbers in narrative footnotes but use numerals in parenthetical references or tables. This flexibility allows editors to tailor their preferences to the specific needs of each article while maintaining a polished final product.
Training and communication are critical components of how editors enforce their preferences. During the editing process, junior editors are often instructed to follow the journal’s specific guidelines on number formatting, ensuring that senior editors’ preferences are consistently applied. This hierarchical structure ensures that editorial decisions are implemented uniformly across all articles. Additionally, editors may provide authors with detailed style sheets or feedback letters, clarifying expectations regarding number formatting in footnotes.
Ultimately, the editorial preferences of law review editors regarding number formatting in footnotes are a reflection of their journal’s identity and commitment to excellence. While external style guides offer a framework, editors’ decisions are shaped by practical considerations, such as readability, consistency, and the nature of the content. By influencing these small but significant details, editors contribute to the overall quality and coherence of legal scholarship, ensuring that footnotes—often the backbone of legal analysis—are both functional and polished.
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Frequently asked questions
Yes, numbers in footnotes of law review articles are often written out in words, especially for numbers below ten, following traditional legal writing conventions.
No, requirements vary by style guide. Some, like The Bluebook, recommend writing out numbers below ten, while others may allow numerals depending on the context.
Yes, ordinal numbers are typically written out in words in footnotes, consistent with the general rule for numbers in legal writing.
Yes, exceptions include statistical data, page numbers, or when the number is part of a specific citation format, where numerals are often preferred for clarity.







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