Written by attorneys · grounded in primary & secondary sources — see below
A citational signal used in legal writing to direct the reader to material appearing later in the same document or text.
Sources & Authorities· 20 primary sources
Select any source to read its text and confirm it supports the definition.
Cases
Statutes
Federal Rules
How it applies
Common Examples
6
Political Contribution Inquiry
A law firm partner prepares a memo analyzing whether contributions to judicial candidates could affect eligibility for government contracts. The partner notes the relevant ethics analysis infra and applies the rule to facts involving Inertia Dynamics seeking municipal bond work after making donations.
Negligence Standard Applied
Israel Irving sues a contractor after a scaffold collapse. Counsel's brief sets out the duty of care and states that the unreasonable risk analysis appears infra, applying the standard to the contractor's failure to secure the equipment properly.
Indigo Textiles holds a junior mortgage on an office building. Its counsel files a brief explaining rent allocation rules and directs the reader to the priority analysis infra, applying the rule to rents collected before a senior receiver takes over.
Contributory Negligence Defense
Ivy Ibarra is injured in a car accident and sues the other driver. Defense counsel's memorandum outlines the plaintiff's duty of self-protection and places the cooperating cause discussion infra, applying the standard to her failure to brake in time.
Rent Retention Rights
Ironclad Industries, as junior mortgagee, obtains a receiver who collects net rents. Counsel's motion cites the retention rule and states the senior mortgagee priority analysis appears infra, applying the rule to the $50,000 collected before the senior receiver is appointed.
Landmark Regulation Challenge
Penn Central challenges the city's landmarks law restricting air rights development. Counsel's brief explains the takings analysis and places the comparison to prior air rights cases infra, applying the rule to the denial of the proposed tower above Grand Central.
Penn Central Transportation Co. et al. v. New York City438 U.S. 104, 98 S.Ct. 2646, 57 L.Ed.2d 631 (1978)
Common questions
Frequently Asked
1
When should a writer use infra instead of supra in a legal memorandum?+
Infra signals that the cited material appears later in the same document. Supra is used for earlier material. Internal cross-references rely on these signals only in citations, not in the body text.
Supporting sources
410 U.S. 113 (1973)Constitutional Law
…problem after 1527; and that the preamble to the English legislation of 1803, 43 Geo. 3, c. 58, § 1, referred to in the text, infra , at 136, states that "no adequate means have been hitherto provided for the prevention and punishment of such offenses." [^maj-27]: Commonwealth v. Bangs , 9 Mass. 387, 388 (1812);…