Garner, however, advocates using notes instead of inline citations. Posner has also written against the use of notes in judicial opinions. He prefers to keep all citations within the text (which is permitted in American legal citation). Legal writing įormer Associate Justice Stephen Breyer of the Supreme Court of the United States is famous in the American legal community for his writing style, in which he never uses notes. NASA has guidance for footnote usage in its historical documents. The US Government Printing Office Style Manual devotes over 660 words to the topic of footnotes. Aggressive use of this strategy can lead to a text affected by "foot and note disease" (a derogation coined by John Betjeman).
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