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An Introduction to The Bluebook

Overview

Rule 22 provides guidance on citing legal materials from Tribal Nations, reflecting their unique legal status and sovereign authority within the United States. This rule is new to the 22nd edition of The Bluebook and addresses a wide range of materials including constitutions, codes, resolutions, and court decisions. 

Tribal Nations are diverse in legal structure and practice. When a Tribal Nation has its own citation format, use it as the primary citation and include a Bluebook-style citation in brackets (Rule 22.1). When no such format is provided, follow the guidance in Rule 22.2.

Use Rule 22 to cite sources such as:

  • Constitutions: Rule 22.2.1
  • Codes: Rule 22.2.2
  • Resolutions and ordinances: Rule 22.2.3
  • Cases: Rule 22.2.4
  • Treaties: Rule 22.2.5; see Rule 21.4 for guidance on citing treaties involving Tribal Nations

For short citation forms, use Rule 22.3, which align with general Bluebook rules for the same material types (e.g., Rule 10.9 for cases, Rule 12.10 for statutes). 

Tip: Commercial databases do not reliably publish tribal court decisions. Use URLs and include Perma.cc links when possible.

Additional Resources