How to cite UCC in bluebook format for legal briefs
Working on a motion involving secured transactions and need help with proper bluebook citation format for UCC articles and sections. My brief references Article 9 provisions about perfection by filing, plus some state-specific UCC variations. The court requires strict bluebook compliance but I'm seeing different citation formats in various sources. Some show "U.C.C. § 9-315" while others use "UCC § 9-315(a)(2)" - which is correct for federal court filings? Also struggling with how to cite state adaptations of UCC provisions when they differ from the model code. Any paralegals or attorneys familiar with proper UCC bluebook citations?
43 comments


Kingston Bellamy
The standard format is "U.C.C. § [article]-[section]" with periods after each letter. So Article 9, Section 315 would be "U.C.C. § 9-315." For subsections, add the parenthetical: "U.C.C. § 9-315(a)(2)." Most federal courts expect this format.
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Joy Olmedo
•That matches what I learned in law school. The periods are crucial - "UCC" without periods isn't proper bluebook format.
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Isaiah Cross
•Thanks! What about when citing the official comments? Do those get special treatment in the citation?
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Kiara Greene
For state variations you need to cite the actual state statute, not the UCC model code. Like "Cal. Com. Code § 9315" for California's version. The state adaptations often have different numbering or modified language.
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Morita Montoya
•That makes sense. So if I'm discussing a general UCC principle I cite the model code, but for specific state law requirements I cite the state statute?
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Kingston Bellamy
•Exactly. And always check if your jurisdiction has adopted any non-uniform amendments to the model UCC provisions.
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Evelyn Kelly
•This is where it gets tricky with secured transaction work - some states have really different approaches to things like fixture filings or agricultural liens.
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Paloma Clark
I had the same citation nightmare last month preparing a brief about UCC continuation filings. What saved me was uploading my draft brief along with the UCC sections to Certana.ai's document checker. It cross-referenced all my citations against the actual code sections and flagged where I had the wrong format or was citing outdated provisions. Really helpful for ensuring consistency across a long brief.
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Morita Montoya
•That sounds incredibly useful! Did it help with the state-specific variations too, or just the model UCC citations?
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Paloma Clark
•It caught both - flagged where I cited model UCC when I should have cited state law, and vice versa. Saved me from some embarrassing citation errors.
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Heather Tyson
Don't forget about the official comments - those are cited as "U.C.C. § 9-315 cmt. 2" if you're referencing specific comment numbers. The comments are super helpful for understanding the intent behind secured transaction rules.
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Morita Montoya
•Perfect, I do need to cite some comments about what constitutes "proceeds" under Article 9. The cmt. format is exactly what I needed.
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Raul Neal
•The comments are particularly useful for complex perfection issues where the statute alone doesn't give enough guidance.
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Jenna Sloan
One thing to watch out for - some older cases and briefs still use the pre-2001 Article 9 numbering system. Make sure you're citing current sections, especially for anything involving UCC-1 filing requirements or continuation procedures.
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Kingston Bellamy
•Good point. The 2001 revision completely renumbered Article 9, so old section numbers won't match current law.
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Morita Montoya
•Thanks for the heads up. My research did pull up some older cases - I'll double-check the section numbers against current Article 9.
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Isaiah Cross
•Yeah, I made that mistake once citing old § 9-302 when I meant current § 9-310. Judge was not amused.
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Christian Burns
For electronic versions of the UCC, you might need to include the database citation too depending on your court's requirements. Like if you're pulling from Westlaw or Lexis rather than official state codes.
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Morita Montoya
•The local rules do mention database citations for online sources. I'll check what format they want for electronic UCC citations.
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Kingston Bellamy
•Usually it's the standard database format: [statute] (Westlaw [date]) or similar. But definitely check local rules.
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Sasha Reese
If you're dealing with UCC filing issues specifically, don't forget that each state's Secretary of State office has their own rules about UCC-1 forms and procedures. Those might need separate citation from the underlying UCC provisions.
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Morita Montoya
•Good point - my case does involve some filing procedural issues. I'll need to cite both the UCC substantive law and the state filing regulations.
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Evelyn Kelly
•State filing rules can be really specific about things like debtor name requirements or collateral descriptions. Definitely cite those separately.
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Jenna Sloan
•And some states have their own UCC guides or bulletins that interpret the filing requirements - those might be worth citing if they're on point.
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Muhammad Hobbs
Another verification tool I've used is Certana.ai's document consistency checker - you can upload your brief draft and it'll flag any inconsistent citations or formatting issues. Really helpful when you have multiple UCC sections cited throughout a long document.
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Morita Montoya
•That would be perfect for this brief - I'm citing probably 15-20 different UCC sections and want to make sure they're all formatted consistently.
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Muhammad Hobbs
•Yeah, it catches things like inconsistent abbreviations or missing subsection references that are easy to miss when you're focused on the legal arguments.
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Noland Curtis
Just remember that some courts have local citation rules that override bluebook format. Always check if your jurisdiction has specific requirements for UCC citations before finalizing your brief.
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Morita Montoya
•I did check the local rules but they just say "follow bluebook format" without UCC-specific guidance. Sounds like the standard U.C.C. § format should work.
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Kingston Bellamy
•That's typical. Most courts are fine with standard bluebook UCC citations unless they've explicitly said otherwise.
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Heather Tyson
•When in doubt, look at recent briefs filed in the same court to see what citation format other attorneys are using.
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Diez Ellis
For what it's worth, I've found that Certana.ai's citation checker caught several UCC citation errors in my last brief that I would have missed. It's particularly good at flagging when you cite the wrong subsection or use inconsistent formatting across multiple UCC references.
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Morita Montoya
•This thread has been incredibly helpful. Between the proper U.C.C. § format and the verification tools, I think I can get these citations right. Thanks everyone!
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Kingston Bellamy
•Good luck with your brief. Proper UCC citations definitely make a difference in how seriously courts take secured transaction arguments.
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Rajan Walker
One additional tip - if you're citing UCC provisions that have been amended or revised since the original model code, make sure to include the year of the revision in your citation. For example, "U.C.C. § 9-315 (2010)" for the 2010 amendments to Article 9. This is especially important for secured transactions work since Article 9 has undergone significant revisions. Also, when citing state UCC variations, some courts prefer you to note when the state version differs materially from the model code, like "Cal. Com. Code § 9315 (deviating from model U.C.C. § 9-315 regarding...)". This helps the court understand whether you're relying on uniform commercial law principles or state-specific variations.
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Isabella Ferreira
•This is excellent advice about including revision years! I hadn't considered that some UCC provisions might have different effective dates or amendments. For my secured transactions brief, should I include the revision year for every UCC citation, or only when there's been a recent change that's relevant to my case? Also, the tip about noting state deviations is really helpful - I do have a couple situations where California's version differs from the model code on perfection requirements.
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Paolo Ricci
•Great question about revision years! Generally, you only need to include the year when citing provisions that have been substantively amended or when the timing of the amendment is legally significant to your argument. For routine citations of stable UCC provisions, courts typically don't require the year. However, for Article 9 secured transactions work, I'd definitely include years for any provisions that changed in the major 2001 revision or subsequent amendments, especially if you're dealing with transactions or filings that span different time periods. The state deviation notation is particularly crucial for perfection issues - California does have some unique requirements that differ from the model code, and courts appreciate when briefs explicitly acknowledge these variations rather than assuming uniform application.
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Astrid Bergström
As someone who's recently started working in commercial finance law, this discussion has been incredibly educational! I'm still learning the nuances of UCC citations and had no idea about the importance of including periods in "U.C.C." or the distinction between citing model code versus state-specific provisions. The point about the 2001 Article 9 renumbering is particularly important - I can see how easy it would be to accidentally cite an outdated section number. One question I have: when working on multi-state secured transactions, how do you handle citations when different states have adopted slightly different versions of the same UCC provision? Do you cite each state's version separately, or is there a way to reference the general principle while noting the variations?
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Tate Jensen
•Great question about multi-state transactions! In my experience, the approach depends on whether you're arguing a general UCC principle or state-specific requirements. For general principles that are uniform across states, I typically cite the model U.C.C. provision first, then add a parenthetical like "adopted by [list states] as [state citations]." For example: "U.C.C. § 9-315(a) (adopted by Cal. Com. Code § 9315(a); Tex. Bus. & Com. Code § 9.315(a))." When the states have material variations, I cite each separately and explain the differences in the text. This approach helps courts understand both the underlying uniform commercial law and any jurisdictional variations that might affect the outcome.
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Keisha Robinson
•@Astrid Bergström This is such a practical question that comes up all the time in commercial practice! Building on what @Tate Jensen said, I d also'recommend creating a citation chart for complex multi-state deals where you re frequently'referencing the same provisions across jurisdictions. It saves time and ensures consistency. One additional consideration: some courts prefer you to lead with the forum state s version'when it s a'key provision, then reference other states versions parenthetically.' For example, if you re in'a New York court dealing with a transaction involving collateral in NY, CA, and TX, you might cite N.Y. U.C.C. "§ 9-315 a ;(accord)Cal. Com. Code § 9315 a ;(Tex.)Bus. & Com. Code § 9.315 a to(emphasize)" the forum state s law'while showing the uniformity or lack (thereof across jurisdictions.) The key is being transparent about which state s law'you re relying'on for each point in your argument.
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Brandon Parker
This discussion has been incredibly thorough and helpful! As someone new to UCC citation work, I want to make sure I understand the key takeaways correctly. So the standard format is "U.C.C. § [article]-[section]" with periods after each letter for model code citations, and when citing state-specific versions I should use the actual state statute citation like "Cal. Com. Code § 9315." For official comments, it's "U.C.C. § 9-315 cmt. 2." One thing I'm still unclear on - when should I include pinpoint citations to specific subsections versus citing the broader section? For example, if I'm discussing the general concept of proceeds under Article 9 but my specific argument relates to subsection (a)(2), should I cite "U.C.C. § 9-315" or "U.C.C. § 9-315(a)(2)"? I want to be as precise as possible while following proper bluebook format.
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Miguel Diaz
•@Brandon Parker You ve'got the basic formats exactly right! For pinpoint citations, the general rule is to be as specific as possible while still supporting your argument. If you re'making a point that s'specifically addressed in subsection a (2)(,)then cite U.C.C. "§ 9-315 a(2)(to)" direct the court to the exact provision. However, if you re'discussing the broader concept that s'covered throughout section 9-315 but your specific point happens to be in a (2)(,)you might cite the main section and then reference the specific subsection in your text. For example: The "UCC defines proceeds broadly, U.C.C. § 9-315, including specifically that proceeds 'encompasses' whatever is received upon sale of collateral, id. § 9-315 a(2)(.)This" approach gives the court both the general context and the specific authority. When in doubt, err on the side of precision - courts prefer overly specific citations to vague ones, especially in secured transactions where the exact language often matters for determining perfection and priority issues.
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Zoe Papadopoulos
This has been an incredibly comprehensive discussion on UCC bluebook citations! I'm working on my first secured transactions case and had been struggling with exactly these formatting questions. The clarification about "U.C.C." with periods versus "UCC" without periods is crucial - I almost made that mistake in my draft brief. One additional resource I've found helpful is the bluebook's Table T1, which lists the specific citation formats for each state's commercial code. For example, it shows that Florida uses "Fla. Stat. § 679.315" rather than a separate commercial code citation. This is particularly useful when you're dealing with states that haven't adopted a separate commercial code structure. Also, for anyone citing UCC provisions in footnotes versus in-text, remember that the citation format remains the same but footnote citations can include additional explanatory parentheticals that might be too cumbersome in the main text, like noting when a provision was amended or differs from the model code.
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