# Id. and Supra in a Table of Authorities: Which Pages to List

> Id., supra and short cites never get their own TOA entry: their pages go to the full authority. Rules, a worked example, footnotes and common errors.

*Updated: 2026-09-24*

**The short answer:** In a table of authorities (TOA), *Id.*, *supra*, “hereinafter” names and short forms such as *Rehaif*, 588 U.S. at 234 are never entries of their own. Each one is another citation to an authority already cited in full, so the page where it appears is added to that authority's single entry. *Id.* goes to the immediately preceding authority; *supra* and hereinafter names go to the source they point back to; a short cite or a reference by case name alone goes to the full case. The one trap: *Id.* § 924(a)(2) after a cite to 18 U.S.C. § 922(g) is a different section, so it is a new statute entry.

Last verified: 2026-09-24. This is formatting guidance, not legal advice; follow your court's rules and your firm's style guide.

**Fast facts**

- One entry per authority, written as the full citation. Every later reference adds a page to that entry.
- *Id.* refers to the immediately preceding authority (Cornell LII, Basic Legal Citation § 6-500). Its page is credited to that authority.
- *Supra* points back to an authority cited in full earlier; under Bluebook Rule 4.2(a) it is not used for cases or statutes, so in briefs it mostly appears with treatises, articles and other secondary sources.
- A “hereinafter” name is set in the first full citation and follows the same limits as *supra*. Its later uses credit the original source.
- References by case name alone (“as *Rehaif* explained”) are the pages most often missed, by people and software alike.
- No national rule governs footnote page references in a TOA. Some briefs write “12 n.4”; others just write “12.”
- The TOA's page numbers are the brief's own printed pages, not reporter pin cites.

## The rule: one entry, every page

[FRAP 28(a)(3)](/table-of-authorities-rules) asks for “references to the pages of the brief where they are cited” ([FRAP 28](https://www.law.cornell.edu/rules/frap/rule_28)), and the Supreme Court's [Rule 34.2](/supreme-court-table-of-authorities) asks for “every page on which an authority is cited” ([Rules and Guidance](https://www.supremecourt.gov/filingandrules/rules_guidance.aspx)). A short form is a citation. So the page where it appears belongs in the table, attached to the full authority. What never appears in the table is the short form itself: no entry reading “*Id.*”, no separate line for “*Rehaif*, 588 U.S. at 234.”

## Id.: credit the immediately preceding authority

*Id.* means the same authority as the one cited immediately before it ([Cornell LII § 6-500](https://www.law.cornell.edu/citation/6-500)). To index it, look back to the last citation, not the last full citation. If the previous cite was itself an *Id.*, keep going back until you reach a named authority. Three cases need care:

- **Id. with a new section.** “18 U.S.C. § 922(g). … *Id.* § 924(a)(2).” The *Id.* stands for title 18, but § 924(a)(2) is a different provision. It gets its own entry under Statutes.
- **Id. after a string cite.** If the preceding citation sentence named several authorities, *Id.* is ambiguous. Read the sentence and credit the authority the writer meant; if you cannot tell, ask the writer.
- **Id. across a page break.** The page is the page where the *Id.* is printed, even if the full cite sits at the bottom of the previous page.

## Supra and hereinafter

*Supra* refers back to an authority cited in full earlier in the document. Under Bluebook Rule 4.2(a) it is not used for cases, statutes and most other primary authority, which have their own short forms ([UC Davis Law Library guide](https://libguides.law.ucdavis.edu/c.php?g=1014499&p=7370559)). In briefs it is common with treatises and law review articles: “LaFave & Scott, *supra*, § 5.1(a).” A hereinafter name, bracketed after the first full citation, works the same way and follows the same limits. For the TOA the rule does not change: the page goes to the entry for the full source, written in full, and the hereinafter name itself never becomes an entry.

## Short cites and name-only references

A short cite such as *Rehaif*, 588 U.S. at 234, or *Greer*, 593 U.S. at 509, credits the full case. So does a textual reference with no reporter at all: “As *Rehaif* explained, knowledge can be inferred from circumstantial evidence.” Most practitioners index those name-only references, because the reader who wants every discussion of *Rehaif* expects to find that page. Some firms index only citations with a reporter or pin cite. Pick one practice and apply it to every authority. Watch for parties with similar names: two “*United States v.*” cases in the same brief are resolved by the defendant's name, never by “*United States*” alone.

## Citations in footnotes

No federal rule we know of says how to show a footnote in a TOA page list, and conventions vary. Three are common: list the page only (“12”); add the footnote number in Bluebook pin-cite style (“12 n.4”), which borrows the “n.” form used to cite a footnote in a source ([Tarlton Law Library](https://tarlton.law.utexas.edu/bluebook-legal-citation/pages-paragraphs-pincites)); or use a firm-specific pattern. Litera's [Best Authority](/best-authority-alternative), for example, lets users set a footnote pattern so that a citation in footnote 5 on page 16 appears as “16n5” or “16fn5” ([Litera support](https://support.litera.com/article/Best-Authority-Options-557433)). If your court or firm has a style, follow it; otherwise use one form throughout.

## Worked example: from brief text to TOA entry

**Which entry gets which page (excerpts from a hypothetical brief)**

| Brief page | Text in the brief | Page is credited to |
| --- | --- | --- |
| 2 | *Rehaif v. United States*, 588 U.S. 225, 227 (2019). | *Rehaif v. United States*: 2 |
| 3 | *Id.* at 237. | *Rehaif v. United States*: 3 |
| 3 | 18 U.S.C. § 922(g). | 18 U.S.C. § 922(g): 3 |
| 4 | *Id.* § 924(a)(2). | New entry, 18 U.S.C. § 924(a)(2): 4 |
| 5 | *Greer v. United States*, 593 U.S. 503, 509 (2021). | *Greer v. United States*: 5 |
| 6 | *Rehaif*, 588 U.S. at 234. | *Rehaif v. United States*: 6 |
| 6, footnote 4 | 1 Wayne R. LaFave & Austin W. Scott, Jr., *Substantive Criminal Law* § 5.1(a) (1986) [hereinafter LaFave & Scott]. | LaFave & Scott treatise: 6 n.4 (or 6, per your style) |
| 8 | As *Rehaif* explained, knowledge can be inferred from circumstantial evidence. | *Rehaif v. United States*: 8 |
| 9 | LaFave & Scott, *supra*, § 5.1(a). | LaFave & Scott treatise: 9 |
| 9 | *Id.* | LaFave & Scott treatise: 9 (same page, no new reference) |

**The resulting table of authorities**

| Authority | Page(s) |
| --- | --- |
| **Cases** |  |
| *Greer v. United States*, 593 U.S. 503 (2021) | 5 |
| *Rehaif v. United States*, 588 U.S. 225 (2019) | 2-3, 6, 8 |
| **Statutes** |  |
| 18 U.S.C. § 922(g) | 3 |
| 18 U.S.C. § 924(a)(2) | 4 |
| **Other Authorities** |  |
| 1 Wayne R. LaFave & Austin W. Scott, Jr., *Substantive Criminal Law* (1986) | 6 n.4, 9 |

*Rehaif* shows “2-3” because it is cited on both pages (the full cite, then *Id.*), so a range is allowed even under the Supreme Court's rule; pages 6 and 8 are listed separately because it is not cited on page 7. Without the name-only reference on page 8, the entry would be incomplete. The cases are real ([*Rehaif*](https://www.law.cornell.edu/supremecourt/text/17-9560); [*Greer*](https://www.law.cornell.edu/supremecourt/text/19-8709)); the brief pages are illustrative.

## Common errors

- **Listing Id. or a short form as its own entry**, or leaving its page out of the full authority's entry.
- **Crediting Id. to the last full citation** instead of the last citation. An intervening statute cite changes what *Id.* means.
- **Treating Id. § 924(a)(2) as § 922(g).** A new section is a new entry.
- **Trusting Word's “Next Citation” button.** Georgetown Law's guide warns that it “will pass over any citations that don't include either a ‘v.’ or ‘§’ symbol, including certain short form citations (e.g. ‘Id. at 5’)” ([Georgetown guide, PDF](https://www.law.georgetown.edu/wp-content/uploads/2018/07/How-to-Build-A-Table-of-Authorities-and-Table-of-Contents-in-Word-2016-1.pdf)). Drake Law Library describes it as searching for “v., Id., In re, and §” ([Drake guide](https://libguides.law.drake.edu/briefformatting/markcites)). The guides differ, which is the point: check every short form by hand.
- **Assuming “Mark All” caught everything.** Columbia Law's handout says Mark All “does not always work, and it never works with ‘id.’” ([Columbia handout, PDF](https://www.law.columbia.edu/sites/default/files/2020-03/final_toc_and_toa_handout_pdf.pdf)). Microsoft's own instructions mark long and short citations that match the text in the dialog ([Microsoft Support](https://support.microsoft.com/en-us/word/create-a-table-of-authorities)); a short form typed differently will not match.
- **Missing name-only references** such as “as *Rehaif* held.”
- **Writing a range across a gap:** “2-8” when the authority is not cited on every page from 2 to 8.

## How tools handle short forms

**[BriefMark](/briefmark-alternative)** says it finds every case, statute, rule and regulation, “short cites, Id. and supra included,” and writes Word's own TA field codes back into the same .docx so Word builds the table, as published on [its site](https://briefmark.oddwell.tech/). It needs the brief as a Word file and Word to finish the table. **BriefAuthority**, in development, is designed to work from the [final PDF](/table-of-authorities-from-pdf) instead. In an internal pre-launch test on two Supreme Court merits briefs, most page-list misses before review were short references by case name alone, such as “*Rehaif*.” Its [review screen](/how-it-works) is built to show every authority with its pages so you can link *Id.* and *supra* references and merge short forms before export. Specification as designed; confirmed at launch.

> **Where BriefAuthority fits:** [BriefAuthority](/table-of-authorities-generator) is pre-launch and not available to buy yet. It is designed to build a TOA from your final PDF, in the browser, [without uploading](/table-of-authorities-without-uploading) the brief, with a review step for *Id.*, *supra* and short forms. It does not check whether citations are good law. Planned price: free for a brief with up to 8 authorities, $19 per brief, or $149 a year. [Join early access](/early-access).

## Frequently asked

**Do you include Id. in a table of authorities?**

Not as an entry. *Id.* is a citation to the immediately preceding authority, so the page where it appears is added to that authority's entry.

**Where does the page for a supra citation go?**

To the entry for the source the *supra* refers back to, written as its full citation. Under Bluebook Rule 4.2(a), *supra* is not used for cases or statutes, so in briefs it usually points to a treatise, article or other secondary source.

**Do short citations like “Rehaif, 588 U.S. at 234” get their own entry?**

No. The page is added to the full entry, *Rehaif v. United States*, 588 U.S. 225 (2019). The pin cite (234) is a page of the reporter and does not appear in the TOA.

**Should I count a case mentioned only by name?**

Most practitioners do, because the reader looking for every discussion of the case expects that page. Some firms count only formal citations. Choose one approach and apply it to every authority.

**How do I show a citation in a footnote in the TOA?**

Conventions vary and we know of no federal rule on it. Common forms are the page alone (“12”) or the page with the footnote number (“12 n.4”). Follow your court's or firm's style and use one form throughout.

**What if Id. follows a citation to a different section of the same code?**

If *Id.* comes with a new section number, such as *Id.* § 924(a)(2) after 18 U.S.C. § 922(g), it refers to a different provision. Give § 924(a)(2) its own entry.

**Keep reading**

- [Table of Authorities rules](/table-of-authorities-rules) — Categories, order, and what FRAP 28 and Rule 34.2 require.
- [Passim in a table of authorities](/passim-table-of-authorities) — Which courts ban it and what to write instead.
- [Table of authorities order](/table-of-authorities-order) — How to order cases, statutes and other authorities.
- [Table of Authorities from a PDF](/table-of-authorities-from-pdf) — Why page numbers should come from the filed PDF.
- [Word for Mac and the table of authorities](/word-for-mac-table-of-authorities) — Mark Citation on a Mac, and what to do instead.
- [Can ChatGPT make a table of authorities?](/chatgpt-table-of-authorities)

**Sources**

- [Cornell LII — Basic Legal Citation § 6-500 (short forms, id., supra)](https://www.law.cornell.edu/citation/6-500)
- [UC Davis Law Library — Short Citation Forms (Id., Supra, Hereinafter)](https://libguides.law.ucdavis.edu/c.php?g=1014499&p=7370559)
- [Cornell LII — FRAP 28](https://www.law.cornell.edu/rules/frap/rule_28)
- [Supreme Court of the United States — Rules and Guidance (Rule 34.2)](https://www.supremecourt.gov/filingandrules/rules_guidance.aspx)
- [Georgetown Law — How to Build a Table of Authorities in Word (PDF)](https://www.law.georgetown.edu/wp-content/uploads/2018/07/How-to-Build-A-Table-of-Authorities-and-Table-of-Contents-in-Word-2016-1.pdf)
- [Drake University Law Library — Mark Citations for the TOA](https://libguides.law.drake.edu/briefformatting/markcites)
- [Columbia Law School — Table of Contents and Table of Authorities handout (PDF)](https://www.law.columbia.edu/sites/default/files/2020-03/final_toc_and_toa_handout_pdf.pdf)
- [Microsoft Support — Create a table of authorities](https://support.microsoft.com/en-us/word/create-a-table-of-authorities)
- [Litera Support — Best Authority Options (footnote pattern)](https://support.litera.com/article/Best-Authority-Options-557433)
- [Tarlton Law Library — Pages, Paragraphs, and Pincites (footnotes)](https://tarlton.law.utexas.edu/bluebook-legal-citation/pages-paragraphs-pincites)
- [Cornell LII — Rehaif v. United States, 588 U.S. 225 (2019)](https://www.law.cornell.edu/supremecourt/text/17-9560)
- [Cornell LII — Greer v. United States, 593 U.S. 503 (2021)](https://www.law.cornell.edu/supremecourt/text/19-8709)
- [BriefMark — product site (as published 2026-09-24)](https://briefmark.oddwell.tech/)