AI and The Bluebook: Why ChatGPT Falls Short of Traditional Algorithms for Bluebook Legal Citation Formatting

ByEthan IsaacsonPublished inAnalyses & TrendsMarch 26th, 2023

ChatGPT, an advanced AI language model developed by OpenAI, has made significant strides in a wide array of applications, from creating engaging content to passing the bar exam. Despite its impressive achievements, however, ChatGPT is not currently suited for formatting legal citations in The Bluebook style. This article explores the reasons behind this limitation, specifically focusing on the lack of text formatting capabilities and the tendency to create incorrect or non-existent citations.

Text Formatting Limitations

One of the primary reasons ChatGPT is not suitable for formatting legal citations in The Bluebook style is its inability to format text with italics, underlining, or small caps. These formatting options are essential for creating accurate citations that adhere to the rigorous standards set forth by The Bluebook.

For example, The Bluebook requires that case names be italicized or underlined. Similarly, some portions of citations, such as the names of certain authors, books, and periodicals, must be presented in small caps. Without these formatting options, a citation generated by ChatGPT would not conform to the proper style, rendering it incorrectly formatted.

Incorrect Abbreviations and Citations

Another issue with ChatGPT's handling of legal citations is its tendency to incorrectly abbreviate party names in court case citations. For example, when citing the case of Wisconsin Packing Co. v. Indiana Refrigerator Lines, Inc., GPT-4 incorrectly abbreviates the states in the party names to Wis. Packing Co. v. Ind. Refrigerator Lines, Inc., a notable deviation from the extensive and exacting Bluebook formatting rules.

Moreover, and more seriously, ChatGPT may generate incorrect or non-existent reporter volumes and numbers. This is a crucial issue, as accurate citations are vital for legal professionals to locate and reference the appropriate sources. An example of this issue is GPT-3.5 citing a Pennsylvania state court decision, Commonwealth v. Ferrone, as 595 Pa. 291 when, in fact, the correct citation is 302 Pa. Super. 282. This kind of error can have severe and disastrous consequences in legal writing, where precision is paramount.

To its credit, rather than fabricating a non-existent citation, the updated GPT-4 now simply refuses to answer the question, instead replying that “as an AI language model, I do not have access to specific case information,” and advising the “need to search a legal database or use a search engine to access the case details.”

The Achievements of ChatGPT

Despite these limitations, ChatGPT has achieved remarkable success in numerous fields. It has even managed to pass the bar exam, demonstrating a deep understanding of legal principles and an ability to reason effectively. Its capacity to generate engaging content and provide insights on various topics is a testament to its versatility and potential for future growth in the legal sphere.

For instance, ChatGPT can help legal professionals draft persuasive arguments, analyze complex legal scenarios, and even aid in drafting contracts and other legal documents. However, when it comes to The Bluebook citations, its limitations currently preclude its use as a reliable citation generator.


In conclusion, although ChatGPT has proven its value in several domains, it is not currently suitable for formatting legal citations in The Bluebook style. The lack of text formatting capabilities, such as italics, underlining, and small caps, as well as its tendency to create incorrect or non-existent citations, make it an unreliable option for this specific task.

While ChatGPT's advancements are undeniably impressive, traditional algorithms remain the best choice for creating accurate and compliant Bluebook legal citations. As AI technology continues to evolve, future iterations of language models like ChatGPT may eventually overcome these limitations. Until then, legal professionals should continue to rely on established and dedicated Bluebook legal citation tools to ensure the accuracy and integrity of their work.

Analyses & Trends
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