Citing NLRB decisions in legal writing can be challenging for law students, attorneys, and researchers who need to follow the Bluebook citation format. The National Labor Relations Board (NLRB) issues decisions that carry legal authority and are often referenced in labor law cases, academic writing, and briefs. Proper citation ensures clarity, consistency, and professionalism in legal documents. The Bluebook, officially titled The Bluebook A Uniform System of Citation, provides specific rules for citing administrative decisions, including those issued by the NLRB. Understanding these rules helps legal professionals accurately reference NLRB decisions and maintain credibility in their writing.
Overview of NLRB Decisions
The National Labor Relations Board is an independent federal agency responsible for enforcing U.S. labor law, primarily concerning collective bargaining and unfair labor practices. NLRB decisions are published after cases are adjudicated and often include opinions from administrative law judges and the Board itself. These decisions serve as guidance for labor practices, influencing how unions, employers, and courts interpret labor law. Properly citing these decisions using the Bluebook format allows readers to locate the sources efficiently and ensures compliance with professional legal writing standards.
Types of NLRB Decisions
NLRB decisions come in several forms, which affects how they are cited
- Board DecisionsOfficial decisions issued by the NLRB after reviewing cases and administrative law judge findings.
- Administrative Law Judge DecisionsInitial rulings made by judges before Board review.
- Summary DecisionsBrief rulings that may include case summaries or procedural outcomes.
The Bluebook provides guidance for citing each type, but Board decisions are the most commonly referenced in legal writing due to their authoritative status.
Basic Bluebook Citation Format for NLRB Decisions
The Bluebook provides a standard structure for citing NLRB decisions. The basic format generally includes the following elements
- Name of the case
- Volume and reporter abbreviation
- Page number
- Decision date or year
- Pinpoint citations if referring to specific pages
A typical citation for a published NLRB Board decision looks like thisGeneral Motors Corp., 373 NLRB 603 (1963). Here, 373 is the volume number of the NLRB Reporter, NLRB is the reporter abbreviation, 603 is the first page of the decision, and 1963 is the year the decision was issued.
Steps to Cite NLRB Decisions
When citing NLRB decisions, it is important to follow a consistent sequence
- Identify the full case name as written in the decision.
- Locate the NLRB Reporter volume and page number where the decision is published.
- Include the year of the decision in parentheses.
- Use pinpoint citations when referencing a specific passage or page within the decision.
- Italicize the case name, following Bluebook rules for case names.
Citing Unpublished NLRB Decisions
Not all NLRB decisions are published in the official NLRB Reporter. For unpublished or recent decisions, the Bluebook provides guidance on using alternative citation forms. Typically, the citation should include
- Case name
- Designation such as NLRB Dec. or No. followed by the docket number
- Date of the decision
For example, an unpublished decision can be cited asSmith Manufacturing, NLRB Dec. No. 21-45 (Jan. 15, 2021). This format ensures that readers can identify the decision even if it has not been formally reported in a volume.
Pinpoint Citations and Subsequent History
When referencing a specific part of an NLRB decision, include a pinpoint citation, indicating the exact page or paragraph relevant to your argument. Additionally, if a case has a significant subsequent history, such as review by a federal court, include a parenthetical noting the outcome, e.g., (rev’d on other grounds, 123 F.3d 456 (D.C. Cir. 2005)). This practice provides context and ensures the citation reflects the most authoritative and up-to-date information.
Examples of Correct Bluebook Citations
Here are several examples demonstrating how to cite NLRB decisions following Bluebook rules
- Bethlehem Steel Corp., 328 NLRB 350 (1999)– Basic Board decision
- American Airlines, NLRB Dec. No. 12-67 (Mar. 3, 2012)– Unpublished or docketed decision
- Ford Motor Co., 345 NLRB 400, 405 (2005)– Board decision with pinpoint citation
- Delta Airlines, 356 NLRB 900 (2010) (rev’d, 640 F.3d 890 (7th Cir. 2012))– Including subsequent court review
Common Mistakes to Avoid
When citing NLRB decisions using the Bluebook, several common errors occur
- Incorrect reporter abbreviation Ensure NLRB is used and not confused with other reporters.
- Omitting the year Always include the decision year in parentheses.
- Failing to italicize case names Case names should be italicized to follow Bluebook formatting.
- Using incomplete docket information for unpublished decisions Include case number and decision date.
- Ignoring subsequent history Note appeals or reversals when relevant.
Tips for Efficient Citation
To streamline citation of NLRB decisions, consider these tips
- Keep a reference list of frequently cited cases with proper Bluebook formatting.
- Use online legal research tools that provide Bluebook-ready citations.
- Consult the latest edition of the Bluebook to ensure accuracy with new rules.
- Double-check spelling, punctuation, and italics to maintain professional presentation.
Citing NLRB decisions in Bluebook format requires attention to detail and understanding of the specific rules for administrative decisions. The key elements include the case name, reporter volume, page number, decision year, and, if necessary, subsequent history or pinpoint citations. By following these guidelines, legal professionals ensure that their citations are clear, accurate, and consistent with the Bluebook, making it easier for readers to locate the original decision. Whether citing published Board decisions or unpublished docketed rulings, adherence to proper citation format enhances the credibility of legal writing and contributes to effective communication in labor law and related fields.