Written by attorneys · grounded in primary & secondary sources — see below
A citational signal directing the reader to an authority cited earlier in the same document. The signal appears after the pinpoint or parenthetical and replaces a full repeat of the earlier citation.
Sources & Authorities
How it applies
Common Examples
6
Landlord Concealment Claim
Serena Soto sued her landlord after discovering hidden mold. Her brief cited the Restatement section on undisclosed conditions and later referred to the same provision with supra when arguing that the landlord's active concealment extended liability.
Self-Authenticating Seal
Skylar Sullivan offered a state agency document bearing an official seal. Counsel authenticated it under the evidence rule and later used supra when discussing the same seal requirement in the reply brief.
Statute of Frauds Memorandum
Sofia Stern sought to enforce an oral services contract. Her motion cited the Restatement section allowing a later memorandum and invoked supra when returning to that timing rule in the reply.
Select any source to read its text and confirm it supports the definition.
Cases
Statutes
Federal Rules
Uniform Acts
Model Codes
Restatements
Casebooks
Hornbooks
Study Supplements
Servitude Payment Covenant
Sasha Stone challenged an assessment in a common-interest community. The brief cited the Restatement exception for such obligations and used supra when reiterating the carve-out in the conclusion.
Right of First Refusal
Sylvia Santos included a preemptive right in her will. The petition cited the Restatement section on reasonable restraints and referred back with supra when addressing the price and timing conditions.
Privacy Right Citation
Stella Shapiro argued substantive due process in a constitutional brief. After citing Roe v. Wade for the privacy foundation, counsel used supra when linking the same precedent to later marriage and procreation cases.
Roe v. Wade410 U.S. 113 (1973)
Common questions
Frequently Asked
5
When may a writer use supra instead of repeating a full citation?+
A writer may use supra once an authority has already been cited in full earlier in the same document. The signal replaces the full citation and directs the reader back to that earlier reference.
Does supra require a pinpoint citation?+
Supra may be used with or without a new pinpoint. When the writer wishes to direct the reader to a different page or section than the original citation, the new pinpoint follows the supra signal.
How does supra differ from infra?+
Supra refers to material already cited earlier in the document. Infra refers to material that will be cited later. The two signals are opposites and are never used interchangeably.
Can supra be used across separate documents such as a complaint and an answer?+
No. Supra operates only within a single document. A later filing must either repeat the full citation or use a short-form citation appropriate to that new document.
Is supra required or merely optional?+
Supra is optional. A writer may always repeat the full citation. The signal is used for brevity once the reader has already been directed to the authority.
410 U.S. 113 (1973)Constitutional Law
…166 (1944); and child rearing and education, Pierce v. Society of Sisters , 268 U.S. 510, 535 (1925), Meyer v. Nebraska , supra . This right of privacy, whether it be founded in the Fourteenth Amendment's concept of personal liberty and restrictions upon state action, as we feel it is, or, as the District Court…