Citing Gen AI, Part II

Publication Title

Washington State Bar News

Document Type

Article

Abstract

In March 2024, I wrote an article for this column entitled “Citing GenAI.” At that time, ChatGPT was just over a year old, and we had no real rules about how, or even if, we needed to use citations to address the use of generative artificial intelligence (GenAI) in legal writing. But now, two different legal citation guides have released rules about citing GenAI outputs.

Last year, The Bluebook released its 22nd edition and included a new rule—Rule 18.3—that provided some guidance on citing to GenAI. As Professor David Ziff noted in his article “Everything You Need to Know About the New Edition of the Bluebook,” the new rule leaves much to be desired. In fact, he recommended attorneys not use the rule to cite their search processes because it is impractical, can require the disclosure of privileged information, and does not appear to be required for use by practitioners due to its placement in The Bluebook’s Whitepages.

But The Bluebook is no longer the only game in town. In May 2026, the ALWD Guide to Legal Citation published its 8th edition, which includes Rule 42 Generative Artificial Intelligence addressing GenAI citation, too. This article will walk you through the ALWD Guide’s helpful advice.

Link to Full Text

Share

COinS