Written by attorneys · grounded in primary & secondary sources — see below
A citation signal directing the reader to material appearing earlier in the same document or text. It functions as an internal cross-reference that avoids repetition by pointing back to a prior discussion, footnote, or authority.
Sources & Authorities
How it applies
Common Examples
6
Pre-Contract Offer Signed by Offeror
Stephen Shaw sends a signed letter offering to sell land to Sean Steele. After an oral acceptance, Steele's lawyer cites the letter in a later memorandum. The lawyer uses see supra to direct the court to the earlier description of the signed offer as satisfying the statute.
Punitive Damages Ratio Review
Santiago Sanchez sues Sapphire Technologies over a defective product. The trial court awards punitive damages. On appeal the brief cites the constitutional guideposts and uses see supra to refer back to the earlier discussion of the ratio between compensatory and punitive awards.
Select any source to read its text and confirm it supports the definition.
Uniform Acts
Restatements
Hornbooks
BMW of North America, Inc. v. Gore517 U.S. 559, 575, 580-81 (1996)
Interracial Marriage Ban Struck Down
Simon Stern and Sasha Stone, an interracial couple, challenge a state statute. Their brief quotes the equal protection analysis and employs see supra to point the court to the prior paragraph discussing the historical context of the Fourteenth Amendment.
Loving v. Virginia388 U.S. 1 (1967)
Notice to Trust Beneficiaries
Sydney Santos, a trust beneficiary, objects to a proposed distribution. The trustee's response cites the due process requirement and uses see supra to refer back to the earlier statement of the fundamental right to be heard before property interests are affected.
Mullane v. Central Hanover Bank and Trust Co.339 U.S. 306, 313-314 (1950)
Minimum Contacts Analysis
Sentinel Security is sued in a distant forum. Its motion to dismiss cites the fairness factors and deploys see supra to direct the court to the prior paragraph describing the defendant's contacts with the forum state.
International Shoe Co. v. Washington326 U.S. 310, 316 (1945)
Equitable Remedies Limitation
Sterling Manufacturing sues for breach and seeks an equitable accounting. The defendant's brief cites the historical distinction between law and equity and uses see supra to refer the court to the earlier discussion of the clean-up doctrine.
Guaranty Trust Co. v. York[326 U.S.] at 110
Common questions
Frequently Asked
3
When may a writer properly use see supra in a legal document?+
A writer may use see supra to direct the reader to an earlier discussion, footnote, or authority within the same document. The signal avoids unnecessary repetition while maintaining the flow of the argument.
Does see supra require the referenced material to appear on the same page?+
No. The signal simply points to material appearing earlier in the same document, regardless of page number. The reader is expected to locate the prior reference through the document's internal numbering or headings.
Can see supra be used to refer to a case that was cited only in a footnote?+
Yes. The signal may point to any earlier portion of the text, including footnotes, so long as the referenced material actually appears before the signal in the same document.
347 U.S. 483, 74 S. Ct. 686, 98 L. Ed. 873 (1954)Remedies
…The doctrine of "separate but equal" did not make its appearance in this Court until 1896 in the case of Plessy v. Ferguson , supra, involving not education but transportation. American courts have since labored with the doctrine for over half a century. In this Court, there have been six cases involving the "separate…