D.6: Omitted Citations or Footnotes Within an Ellipsis

If the quote uses an ellipsis to omit words from the original source, and these omitted words contain a footnote or citation, you do not need to add a “citation omitted” or “footnote omitted” parenthetical.
The rationale is that the ellipsis is already indicating to the reader that material is being omitted, and there is no need to further indicate this with a “footnote omitted” or “citation omitted” parenthetical.

Author: Jasnoor Hundal In early August 2023, the Supreme Court stayed the Second Circuit Court of Appeals’ decision, In re Purdue Pharma L.P., and granted certiorari to hear oral argument in December of 2023. The parties were asked to brief and argue “[w]hether the Bankruptcy Code authorizes a court to approve, as part of a […]

Randy Kominsky is a member of Temple Law’s Class of 1979. Mr. Kominsky was a staff editor for Volume 51 and an associate research editor for Volume 52 of Temple Law Review. His case note, Housing Discrimination – The Appropriate Evidentiary Standard for Title VIII of the Civil Rights Act of 1968, was published in 1978.[1] After graduating, he moved […]

Disrupting Hierarchies In Legal Education: Increasing Access By Supporting First Gen Success Katharine Traylor Schaffzin, Dean and Professor of Law, University of Memphis Cecil C. Humphreys School of Law The first-generation college students of Generation Z will challenge all of higher education, including legal education, to reconsider the delivery of education. Fortunately, undergraduate institutions have been […]