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Canadian Guide to Uniform Legal Citation (9th Ed.)

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About In-text Citations

In legal writing, the standard way to cite is to use footnotes. In-text citations are only used for memorandums and factums. Properly citing your sources allows readers to follow up and learn more if they are interested, gives credit to the original authors and helps avoid plagiarism (learn more on MacEwan's Academic Integrity page). Make sure that your sources are included in footnotes or citations throughout your paper and in a bibliography at the end of your paper.

McGill Guide in-text citation guidelines are detailed below.

Memorandums

When you cite something in a memorandum, include a reference immediately after the relevant text, in parentheses. Follow normal footnote rules the first time a reference is used, and if the same reference is used multiple times in a row, use ibid from the second use onward (and include a pinpoint if necessary). If the same reference is used again later following other references, use a shortened version of the citation (and include a pinpoint if necessary).

Example:

"The issue at hand pertains to the enforceability of the non-compete clause in the employment contract. To be upheld, a non-compete clause must satisfy the requirements of reasonableness and protectable proprietary interests (Payette v Guay Inc, 2013 SCC 45, para 29 [Payette]). In assessing reasonableness, Canadian courts consider factors such as the geographic scope, duration, and nature of the restriction (RBC Dominion Securities Inc v Merrill Lynch Canada Inc, [2008] 1 SCR 241, para 30). Furthermore, the clause must protect legitimate proprietary interests, such as trade secrets, confidential information, or customer relationships (Payette at para 30). However, an excessively broad or unreasonable non-compete clause may be deemed unenforceable (ibid at para 33). In the present case, the non-compete clause extends beyond a reasonable geographic scope and duration, imposing undue hardship on the employee and impeding their ability to earn a livelihood. Therefore, it is arguable that the non-compete clause in question fails to meet the reasonableness requirement and should be deemed unenforceable."

Factums

Paragraphs in a factum must be numbered. Each source cited requires a short form citation, which is to be included in parentheses immediately following the relevant text. The complete reference is included at the end of each paragraph, in smaller, indented text, with references listed in the order they appear in the text.

Following the first full citation of each source in the references include the short form citation in brackets. If a reference is repeated, use the short form citation with the word supra (eg., Brown, supra para 2 at para 14). Factums do not use ibid.

Example:

1.   The issue at hand pertains to the enforceability of the non-compete clause in the employment contract. To be upheld, a non-compete clause must satisfy the requirements of reasonableness and protectable proprietary interests [Payette]. In assessing reasonableness, Canadian courts consider factors such as the geographic scope, duration, and nature of the restriction [RBC]. 
Payette v Guay Inc, 2013 SCC 45, para 29 [Payette].
RBC Dominion Securities Inc v Merrill Lynch Canada Inc, [2008] 1 SCR 241, para 30 [RBC].
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