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how to footnote in an essay

Using Footnotes: The Dos And Don’ts

(Last updated: 29 August 2018)

Since 2006, Oxbridge Essays has been the UK’s leading paid essay-writing and dissertation service

We have helped 10,000s of undergraduate, Masters and PhD students to maximise their grades in essays, dissertations, model-exam answers, applications and other materials. If you would like a free chat about your project with one of our UK staff, then please just reach out on one of the methods below.

In university, your ability to reference sources correctly will have a considerable impact on the mark you receive. The rules you must follow can be tricky to grasp initially, but if you do ever need a quick recap then Oxbridge Essays are always happy to help and give your work a going over to pick up any tiny errors.

The difference between a footnote and a bibliography

Mistakes with footnotes are common . Some students choose to use footnotes without having a firm grasp of how they should be used, or what they should be used for. As a general rule, if you’re not 100 percent sure how a footnote should be used, it’s best not to use one at all.

Footnotes should be included to provide the reader with additional information about the content. The footnote is found at the bottom of the page, and is referenced through a superscript number within the main body of your copy.

The bibliography page is the last section of your essay or dissertation and includes the full citation information for any source cited or referenced through the course of your work. The information contained within a bibliography will provide the reader with full details of the work, including when and where the source was published. A footnote might only include the title of the source.

How to use footnotes correctly

Write your footnotes last – A footnote is commonly, but not always, a shortened version of a citation contained in your bibliography. Whatever content you choose to include, it’s usually best to leave your footnotes until the essay is finished and your bibliography is complete. Place a short reminder in the form of a comment or even a brief footnote to prompt you to fill these in later.

You still need a bibliography – With the occasional exception found in the Oxford referencing system, the use of footnotes does not replace the need for a bibliography at the end of your essay, despite the fact that extensive footnotes can make them seem superfluous. Remember that your bibliography should include all of your reading, and everything that has informed your essay, even if they are not directly referenced. Doing so will prove you’ve done your research too.

Double-check footnotes can be used – Different universities and referencing styles all have their own take on footnotes, so before you start listing footnote citations, check they are actually allowed. Typically, British universities prefer the use of in-text citations.

Footnotes and different referencing styles

Using the Harvard system , which is the predominant form of referencing at universities in the UK, sources are cited in short, parenthetical notes within the text. Footnotes are not allowed. Citations within the text should include the name of the author, the date of the source, and, if necessary, the page numbers you used. The rest of the information, such as the title and publication details, should be included in the bibliography.

Using the Oxford system , citations in the text usually consist of a superscript number which relates to a footnote at the bottom of the page. If you write full bibliographic information in the footnote, you may not have to include a bibliography. However, it’s well worth checking with your tutor beforehand.

When you reference a source in a footnote for the first time using the Oxford system, you must provide full bibliographic information, which includes:

  • Author’s initials and surname, title of the article, book or journal, editor (if applicable), publisher name, location and year published

The Chicago citation style , established by the University of Chicago Press, is probably the most commonly used footnote format. Guidelines to help you avoid mistakes with footnotes include: always include a full citation the first time you reference a source; cite author’s names as they appear with texts; don’t replace names with initials; and if no author is listed, organise the entry by title.

A Chicago style footnote citation will take the following form:

  • Author’s first name and last name, title in italics, city of publication, publisher and year, page number if relevant.

Don’t forget footnotes

It’s easy to get caught up in the act of writing your essay, but it’s imperative that you include full footnotes and proper referencing whenever possible , as that is what separates academic writing from opinion. At Oxbridge Essays, we know a thing or two about how to use footnotes. And if you have an essay you need a little help with, we can provide full referencing in your chosen style, so get in touch for help.

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How to Use Footnotes and Endnotes

4-minute read

  • 5th June 2019

Footnotes and endnotes both let you add extra information in an essay or college paper . But what should you include in these notes? And when should you use them? In this post, we run through everything you need to know about using footnotes and endnotes in academic writing.

What Are Footnotes and Endnotes?

Footnotes appear at the bottom or “foot” of the page. You can therefore put extra information in a footnote, such as source details for a citation, without interrupting the flow of the main text.

To indicate a footnote, you can add a superscript number to the text, such as at the end of this sentence. 1 These numbers then correspond to numbered notes at the bottom of the page.

A footnote or three.

Endnotes are like footnotes, but they appear together at the end of the document rather than at the bottom of each page. Endnotes are thus less immediately accessible for the reader than footnotes, but they can help ensure that pages with multiple notes don’t become cluttered.

If you are not sure which to use, check your style guide for advice.

Footnotes and Endnotes in Microsoft Word

To insert a footnote or endnote in a Microsoft Word document, you need to:

  • Go to References > Footnotes on the main ribbon
  • Select either Insert Footnote or Insert Endnote as required
  • Type your note in the newly created footnote/endnote

Footnote tools in MS Word.

You can also customize the style of footnotes and endnotes by clicking on the arrow in the bottom right of the Footnotes section of the References tab (or by going to Insert > Footnotes in Word for Mac ). This will open a new window where you can select your preferred formatting options.

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When to Use Footnotes and Endnotes

The main uses of footnotes and endnotes are as follows:

  • To add a footnote citation in referencing systems such as MHRA and Chicago , with full source information also given in a bibliography at the end of the document. Endnotes are also used for citations in some systems, such as in IEEE or Vancouver referencing, where numbers in the text point to an entry in a reference list at the end of the document.
  • To add non-essential commentary on something in the main text of your document. For example, if your research has raised an interesting question that is not directly relevant to your current work, you could mention it in a footnote or endnote. This lets you acknowledge the question – showing the reader that you haven’t simply ignored or failed to notice it – but without interrupting the flow of prose in the main document.

Keep in mind, too, that some referencing systems use in-text parenthetical citations . As such, you should only reference a source in a footnote or endnote if your school has asked you to do it this way.

Do Notes Count Towards the Word Limit?

We’re often asked whether to include footnotes and endnotes in the word count for papers. Different schools have different rules about this, so you will have to check your style guide . However, you should never use these supplementary notes to cheat the word count.

The key here is that essential information should never go in a footnote or endnote. If you do move vital evidence or analysis to a note, the person marking your work may ignore it. And reducing the word count is never more important than putting forward a full, coherent argument.

If you do need to reduce the word count in an essay, you have other options, such as rewriting wordy sentences or cutting repetition. Having your work proofread is a great way to ensure that your writing is always clear and concise, too, so let us know if you’d like any help.

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What Are Footnotes and How Do You Use Them?

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Written by  Scribendi

While reading a book or article, have you ever noticed little numbers placed at the ends of some sentences?

These numbers usually appear as superscripts and correspond with numbers placed at the bottom of the page, next to which appears further information that is both necessary and supplementary. Sometimes this information will come in the form of citations, but sometimes it will simply present additional notes about the topic at hand.

These citations and explanations are called "footnotes" (because they appear in the footer of the page). Take a look at the example below to see where footnotes appear on a page:

Footnote Example

We've outlined how to use footnotes below. Check it out!

1. What Are Footnotes?

2. footnotes vs. endnotes, 2.1 should i use footnotes or endnotes, 3. how to do footnote citations, 3.1 in-text citations, 3.2 footnotes, 4. how to use footnotes in essays, 4.1 style guides, 4.1.1 modern language association (mla), 4.1.2  american psychological association (apa), 4.1.3  chicago manual of style (cms), 5. technical guide to using footnotes, 5.1 how to add footnotes in microsoft word, 5.2 how to add footnotes in google docs, 6. final tips and tricks .

Footnotes are notes that are placed at the end of a page and used to reference parts of the text (generally using superscript numbers). Writers use footnotes for several purposes, including  citations , parenthetical information, outside sources, copyright permissions, background information, and more.

Now that you understand what footnotes are, you might be wondering: why use them? The truth is, long explanatory notes can be difficult for readers to trudge through (especially when they occur in the middle of a paper). Providing this information is necessary, but doing so in the main text can disrupt the flow of the writing.

Imagine if every time an author wanted to provide a citation, the entire citation had to be written out at the end of the sentence, like this (Anthony Grafton, The Footnote: A Curious History [Cambridge, MA: Harvard University Press, 1999] 221). Books would become much longer and reading would be much more tedious. That's why footnotes are so useful: they let authors provide the required information without disrupting the flow of ideas.

While footnotes are a great resource for sharing information without clogging up the writing, it's important to note that certain style guides restrict when footnotes can be used. We'll get into that soon!

Unsure how to edit your paper? Contact the Scribendi team for professional proofreading .

Authors can also use endnotes to avoid disrupting their writing with extraneous information. Both serve similar purposes; the main difference lies in their location in your text. Here's a closer look at how both footnotes and endnotes work.

  • Identified in the main text with a small superscript number
  • Used for citations, parenthetical information, outside sources, copyright permissions, background information, and more
  • Provide the correlating notes at the bottom of the same page
  • Identified in the main text with a small superscript number (like footnotes)
  • Used for citations, parenthetical information, outside sources, copyright permissions, background information, and more (like footnotes)
  • Found collectively at the end of an article, chapter, or document (unlike footnotes)

When deciding  whether to use footnotes or endnotes , authors must consider three main factors:

  • The style guide being used (as some require either footnotes or endnotes)
  • The number of notes being included (as having too many footnotes on each page can be distracting)
  • Which option will be more convenient for the reader

To make a footnote citation, label the area of your text that you need to reference with a number (if it's your first footnote, start with "1."). At the bottom of the page, include this number with the citation. When readers see the number in the text, they know they can find the source by looking for the corresponding footnote.

Here's an example of a quoted piece of text using in-text citations vs. footnotes.

"Like the high whine of the dentist's drill, the low rumble of the footnote on the historian's page reassures" ( The Footnote: A Curious History [Cambridge, MA: Harvard University Press], 1999. pg. 1).

"Like the high whine of the dentist's drill, the low rumble of the footnote on the historian's page reassures." 1

[Text continues]

Bottom of the page:

1. The Footnote: A Curious History [Cambridge, MA: Harvard University Press], 1999. pg. 1

The exact format of your footnote depends on   the style guide  you're following. Here are some of the most common style guides for writing papers, as well as the footnote rules for each one.

Of the major style guides, The Chicago Manual of Style (CMS) uses footnotes most often. However, footnotes are occasionally employed in other style guides as well. The main difference is that, while CMS uses footnotes for citation purposes, the Modern Language Association (MLA) and the American Psychological Association (APA) generally rely on them for the provision of additional information.

While MLA style discourages the use of long footnotes or endnotes, the style guide does permit their use for directing readers to other pertinent information on a relevant subject.

The guide recommends that superscript numbers within the text are placed outside any punctuation that might be present (i.e., after a period if the note is at the end of a sentence and after a comma if the note is at the end of a clause). The exception to this is that the superscript numbers should be placed before dashes.

  • When a footnote must be placed at the end of a clause, 1 add the number after the comma.
  • When a footnote must be placed at the end of a sentence, add the number after the period. 2
  • Numbers denoting footnotes should always appear after punctuation, with the exception of one piece of punctuation 3 —the dash.

4.1.2 American Psychological Association (APA)

Like MLA, APA discourages the use of footnotes unless absolutely necessary. Even then, the guide recommends that footnotes only be used to provide content notes (such as providing brief, supplemental information about the text or directing readers to additional information) and to denote copyright permissions. The rules regarding placement of the in-text numbers is the same in APA as in MLA.

4.1.3 The Chicago Manual of Style (CMS)

Of the three main style guides described here, CMS relies on footnotes the most. While CMS does allow the author–date system of in-text referencing (i.e., providing the author's name and the date of publication in parentheses at the end of the phrase, clause, or sentence that references the work), it also offers a citation style in which footnotes or endnotes are employed. In both cases, bibliographies are also required. Whether an author should use the author–date system or footnotes is often decided by the author's professor, journal, or publisher.

As an example, if footnotes are used, the following format should be adhered to when referencing a book in CMS:

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To use footnotes in your own book, essay, or article, you must first decide on the most appropriate and logical placement of your footnotes in the text. Add numbers according to your chosen style guide, and be sure to add the numbers directly after the phrase, clause, or sentence to which the corresponding footnote refers.

Most online writing programs (such as Microsoft Word and Google Docs) come with easy-to-use tools for inserting footnotes. Here are step-by-step guides to using footnotes in both these programs.

5.2 How to Add Footnotes in Microsoft Word

Here's how to use footnotes in Microsoft Word 2021:

  • Click on the place in the text where you want the first footnote to appear.
  • Under the References tab, you'll see the following symbol: AB.1. Beneath this symbol is a button with the words, "Insert Footnote." Click it to create your first footnote.
  • After you click that button, two numbers should appear: one number should appear in the main text, and the corresponding number should appear at the bottom of the page.
  • Write your citation or additional information next to the number that appears in the footer. Format the information according to the rules of your style guide.
  • You can easily return to your place in the text by clicking the number at the beginning of the footnote.

Congrats! You've created your first footnote. You can also adjust the footnote settings (like the numbering) by clicking the arrow beside the Footnotes group. It's really that easy!

Here's how to use footnotes on Google Docs:

  • Under the Insert tab, click on "Footnotes."

All you really have to do to create footnotes is click a button—it couldn't be easier!

6. Final Tips and Tricks

To  improve your writing  and avoid cluttering the page, you should use footnotes sparingly and only to provide helpful additions or citations. As previously noted, this information may be considered supplementary, which is why it's best to place it away from the main portion of your writing.

When creating your footnotes, always keep reader convenience in mind, and remember that the footnotes are there to convey helpful information. If your footnotes are excessive or unnecessary, readers are likely to become annoyed—they may even be distracted from the main points of your writing.

Now that you're no longer asking "What are footnotes?" and you know how to use them according to various style guides, footnotes can become a great asset to you as a writer. Be sure to follow the recommendations above, as well as those of your preferred style guide, to ensure that you're using footnotes to their best effect. Don't forget—if you ever need help with writing, our academic articles are here for you!

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how to footnote in an essay

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MLA Endnotes and Footnotes

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Because long explanatory notes can be distracting to readers, most academic style guidelines (including MLA and APA, the American Psychological Association) recommend limited use of endnotes/footnotes. However, certain publishers encourage or require note references in lieu of parenthetical references.

Bibliographic Notes

MLA discourages extensive use of explanatory or digressive notes. MLA style does, however, allow you to use endnotes or footnotes for bibliographic notes , which refer to other publications your readers may consult. The following are some examples:

To cite a lengthy string of sources.

¹See Said, Culture and Imperialism and Orientalism ; Serres, The Natural Contract ; Foucault, The Foucault Reader , esp. Part II.

²For more material related to Postcolonial Studies and Technology, see McClintock, Imperial Leather ; De Landa, War in the Age of Intelligent Machines.

To explain an unusual documentation practice.

³Italicised words denote translations for which there are no clear equivalents in the original Chinese.

To flag editions and translations used. Editions and translations usually require a note only when more than one edition or translation is cited. This can be done by placing a note in the text where the work is first referenced. Alternatively, an initial and unnumbered note may be created.

⁴Citations of The Odyssey refer to Emily Wilson’s translated version unless otherwise noted.

⁵Translations are provided by Emily Wilson unless otherwise noted.

Content Notes

You can also use endnotes/footnotes for occasional explanatory notes (also known as content notes), which refer to brief additional information that might be too digressive for the main text:

To amplify.  Writers may feel that amplifying certain sections of their content will allow readers to better understand the context which affected/affects the following circumstances. 

¹Kujou and Yanagi are often confused by their misinterpretation of each other’s words, actions, and interactions with others.

²Beach considers Readicide to be a necessary read for all incoming Student Teachers, including it in recommended words for all his students.

³Culler makes it clear that “Literature” is “an institutional label that gives us reason to expect that the results of our reading efforts will be ‘worth it’” (28).

To explain word choice.

⁴She refers here to a branch of physiological research.

⁵He chose to translate the verb (first translated by Yang as “to feel”) as “to understand” to point to the character development.

To justify the scope of your study. Justifying the scope of your study can help readers better understand what to expect from reading your work by specifically pointing to what will or will not be explored, and why.

⁶Whether or not Beowulf as a character is justified in his actions is not relevant to my point.

⁷The efforts of decolonization are beyond the extent of my essay, but I point readers to Garvey’s work.

To provide more examples.

⁸Readers can think about Atwood’s inclusion of insects in her literary work

⁹This same idea applies to queer youth, as Chelsea Monheim’s “Percieved social norms and acceptance of transgender students in gendered restrooms” addresses.

To provide counterexamples.

¹⁰Bankfeld (99-102) calls for an alternative call to action.

To identity of comment on allusions.

¹¹The reference to ‘Westword’ in Iron Man 3 recalls the 1973 movie Westworld, starring Yul Brynner as a killing cyborg.

To point to an area of future research.

¹²More extensive research remains to be done on this subject. 

To identify authors whose names appear as et al. in documentation.

¹³The contributing authors of Teaching Literature to Adolescents are Deborah Appleman, Bob Fecho, and Rob Simon.

To acknowledge.

¹⁴Anna Turner, from a local veterinary clinic, brought distinctions between small and large animal care to my attention.

Numbering endnotes and footnotes in the document body

MLA notes may be styled either as footnotes or endnotes. Endnotes and footnotes in MLA format are indicated in-text by superscript Arabic numbers after the punctuation of the phrase or clause to which the note refers:

Note that when a long dash appears in the text, the footnote/endnote number appears before the dash:

Do not use asterisks (*), angle brackets (>), or other symbols for note references. The list of endnotes and footnotes (either of which, for papers submitted for publication, should be listed on a separate page, as indicated below) should correspond to the note references in the text.   Do not use the abbreviation ibid. in a note to refer readers to the information provided in the note right above it.

Placement of Notes in the Text

Use parentheses around page numbers when page numbers interrupt a sentence or are given at the end of a sentence. Similar to parenthetical citations within text, citations in notes are usually placed at the end of a sentence. Alternatively, parenthetical citations may be placed mid-sentence.

¹As Danes (45) and Gilmore (151) argue, caffeinated beverages play a vital role in American business environments.

²Gilmore considers the relationship between caffeine, productivity, and success (151).

Do not place parentheses around page numbers if the note is utilized to direct readers to the location of information. For example:

³See Gilmore 151.

Notes in MLA format are typically indicated in-text by superscript Arabic numbers (1, 2, 3, …) after the punctuation mark of the phrase or clause to which the note refers. Whenever possible, place the superscript numbers at the end of sentences. Keep in mind that word processing programs will likely style note numbers in the text and notes section as superscript by default .

Audience members generally responded positively to the racial representation in the musical.¹

Marquis de Lafayette uses a stereotypical White American accent to say the word “anarchy.”²

Aaron Burr advises a young Alexander Hamilton to “talk less, smile more” (16).³ 

Note that when a dash appears in the text, the note number appears before the dash.

After finding out about her daughter’s passion for music, Cho⁴—surprised, impressed, and a little confused—purchased a piano and allowed her daughter to take lessons.

If a note number must be placed somewhere other than at the end of a sentence or a sentence requires more than one note, the note number should be placed in the least distracting unambiguous spot. For instance: 

Placement of a note mid-sentence, for clarity of citations.

Despite the awareness from her past mistakes,⁵   Britney “did it again” and thus continued to face the consequences of her actions (203).

Placement of more than one note in a sentence.

Crystal’s love of farmers markets—especially those located in their hometown (which they support by “getting up at 7am every Saturday to go to” [Webb 21]⁶)—has become apparent even on social media platforms.⁷  

Formatting endnotes and footnotes

Endnotes Page

MLA recommends that all notes be listed on a separate page entitled Notes (centered). Title the page Note if there is only one note. The Notes page should appear before the Works Cited page. This is especially important for papers being submitted for publication.

The notes themselves should be double-spaced and listed by consecutive Arabic numbers that correspond to the notation in the text. The first line of each endnote is indented five spaces, and subsequent lines are flush with the left margin. Place a period and a space after each endnote number, and then provide the appropriate note after the space.

Footnotes (below the text body)

The ninth edition of the MLA Handbook states that notes may be styled either as footnotes or endnotes. See the  MLA Style Center   for additional guidance on this topic and follow your instructor's or editor's preferences.

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What Are Footnotes and How to Use Them

By Erin Wright

What are Footnotes and How to Use Them | Image of Flip Flops on a Blue Deck

What Are Footnotes?

Footnotes are supplementary pieces of information that support your writing. If you’re following The Chicago Manual of Style (Chicago style, which is the best style guide for general business content), supplementary information includes works cited, suggestions for further research, commentary, quotations, copyright statements, or a combination of any of the above. 1

If you’re following the Publication Manual of the American Psychological Association (APA style) or MLA style from the Modern Language Association, works cited typically appear in the reference list or bibliography; so, footnotes are reserved for commentary, suggestions for further research, or copyright statements. 2

Work cited example based on Chicago style:

1. Lynne Truss, Eats, Shoots & Leaves (New York: Gotham Books, 2003), 89.

Commentary example:

2. This study excluded Groups D and E; therefore, it should not be considered exhaustive.

Suggestion for further research example:

3. Visit www.erinwrightwriting.com for more information about ampersands.

Where Should Footnotes Appear in Formal Documents?

Footnotes usually appear at the bottom of the page. Each footnote is preceded by a number that also appears as a superscript after the corresponding material on that page. Chicago style allows you to use symbols, such as the asterisk or the dagger, instead of numbers if you only have a few footnotes. 3

If you’re following APA style or MLA style, footnotes can appear at the foot of the page or all together at the end of the document. 4 (In Chicago style and MLA style, notes placed at the end of articles, chapters, or books are called endnotes. 5 ) Unlike Chicago style, APA style and MLA style don’t recommend using symbols as footnote identifiers. 6

Where Should Footnotes Appear in General Business Writing?

If you’re publishing less formal content online, such as a blog post or a how-to article, there’s no rule that says you can’t put footnotes at the end of individual sections. I like to call them “floating footnotes” because they float where they’re most needed instead of languishing at the end of a page or document.

In fact, floating footnotes can be more helpful than traditional footnotes for viewers who only need to read a few sections of your content. Floating footnotes can also benefit viewers who don’t want to scroll all the way to the end of a long webpage or ebook.

However, reserve floating footnotes for longer pieces so your content doesn’t become disjointed. If your blog post or article is only a couple of screen lengths, tradition footnotes should work just fine. You can see an example of a floating footnote in the second-to-last section of Three Ways to Add Currency Symbols in Microsoft Word .

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How to focus on homework, how to write a rhetorical analysis essay, how to do footnotes.

Johannes Helmold

Footnotes are a reference tool for writers and researchers, allowing them to provide additional information, clarify sources, or share related insights without disrupting the flow of the main text. Footnotes are positioned at the bottom of the page and indicated within the text by a superscript number or symbol. Various academic and professional fields rely on footnotes to maintain the credibility of written work. They are prevalent in citation styles such as Chicago, often used in history and the humanities, and MLA, preferred in literature and some social sciences. Footnotes help maintain the integrity of the narrative while providing the reader with access to the source material for verification or deeper exploration.

What Is a Footnote?

A footnote, as the name suggests, is a special note or a comment placed at the bottom of a page within a document that provides additional information, clarification, or citation of sources related to the text referenced by a superscript number or symbol appearing in the main body of the document. The purpose of these messages is to explain, elaborate on, or complement the material without cluttering the main content. It helps readers stay on track of the story and just glance at the bottom of the page at a footnote to get more information, if necessary. Therefore, footnotes allow for a cleaner and more readable narrative.

Footnotes come in various forms, primarily categorized based on their purpose: content footnotes and citation footnotes. 

Content footnotes give further details for better understanding or provide context to a statement made in the main text but are not directly linked to a citation. Informational footnotes are valuable in technical documents, encyclopedias, and detailed analytical works where extra information might be helpful for readers who seek deeper understanding or background knowledge about the discussed topic.

Citation footnotes , on the other hand, are implied when the referencing style of the document prefers footnotes for citation instead of in-text citations or endnotes. Bibliographic footnotes make all the citation details accessible without overcrowding the main text. This is particularly useful in disciplines like history and classical studies, where original sources may be extensively analyzed or critiqued. 

Typically, footnotes appear at the bottom of the same page where their corresponding superscript is noted. This placement is very convenient as readers can easily find and refer to the additional information without having to flip through the pages. It maintains a smooth reading experience while providing depth and evidence where needed.

How to Use Footnotes

To use footnotes in your writing effectively, start by determining when a footnote is necessary or when you believe it may be helpful for readers. Generally, any supporting information that is too detailed for the main text but required for deeper understanding or source verification should be noted in a footnote. This includes direct citations, clarifications, and supplemental data.

Once you decide to add a footnote, insert a superscript number at the end of the sentence or clause related to the additional information. This number should follow any punctuation (except a dash) and be placed directly after the last word of the sentence. In your document’s footer, corresponding to each superscript, you’ll detail the footnote. Each footnote should be concise and directly relevant to the referenced text.

For example, consider a statement in an academic paper:

 

You might use a footnote to cite the sources of this claim or to provide a brief list of historians who support this viewpoint. The footnote might look like this:

How To Do Footnotes

Always start the footnote content flush left at the bottom of the page. If a footnote extends beyond one line, indent the subsequent lines. This formatting helps maintain clarity and improves readability.

Additionally, if you reference the same source multiple times throughout your document, you may use shortened forms of the citation after the first full one, or use “Ibid.” if it’s the immediately preceding citation. This keeps your footnotes focused.

How To Write A Footnote

Writing correct footnotes is a valuable skill and an important part of academic writing. Footnotes allow authors to make their writing more credible by providing additional context, source citations, and relevant commentary. There are several aspects to consider in creating informative and accurate footnotes, including clarity of expression, compliance with a consistent formatting style, and attention to detail in citing sources. 

  • Clarity : Each footnote should be concise. It’s important to provide thorough information, but it’s equally vital to be brief and to the point. Avoid overly complex sentences and focus on the essential details.
  • Consistent Formatting : Stick to a consistent formatting style for your footnotes. This includes the font size, indentations, and the spacing of lines. Consistency in formatting helps maintain professionalism and readability.
  • Use of Signals : Employ standard scholarly signals such as “see,” “cf.,” “compare,” and others to guide the reader on the nature of the citation or comment. For instance, “cf.” (confer) suggests a comparison, while “see” directs the reader to a source that supports your argument.
  • Language Style : Maintain an academic tone that matches the rest of your document. Avoid colloquial language. Your footnotes should enhance the scholarly quality of your paper.
  • Reference Accuracy : Double-check your references for accuracy. A footnote with a citation must include all necessary details, such as page numbers, authors’ names, and publication details, formatted according to the appropriate style guide.
  • Integration with Text : Each footnote should correlate directly with a specific part of the text. This connection should be clear without the reader having to make assumptions about the relevance of the footnote.

All styles use a similar method for creating footnotes based on their purposes and functionalities that we already mentioned. But there are subtle variations and quirks everywhere, as is typically the case with citation issues.

The Modern Language Association style typically uses parenthetical in-text citations rather than footnotes. However, footnotes can still be used in MLA for supplementary comments, additional references, or explanatory notes that might be too wordy for the main text.

When you do need to use a footnote in MLA style, you would insert a superscript number at the end of the sentence containing the information that requires a footnote. This number corresponds to a footnote at the bottom of the page where you provide the additional information or citation. Footnotes in MLA are mainly used to provide readers with further explanations or to cite sources for quotations and factual statements where in-text citations would disrupt the flow of reading.

Consider a sentence from an academic paper:

“Despite its initial failure, the treaty significantly influenced international policy in subsequent years.”

Corresponding Footnote : At the bottom of the page, you would add:

3. While the treaty’s initial reception was lukewarm, historians like Thompson argue that its long-term impact was profound (Thompson 157).

MLA Style footnote example

Here, the superscript “1” directs the reader to the footnote at the bottom of the page, where further details and a source are provided. This helps keep the main text clean, while still offering a way to access extra information and detailed citations.

Similar to MLA, the American Psychological Association (APA) style includes in-text citations. However, footnotes may be used for additional material or private correspondence not included in the reference list. APA footnotes are also used for additional comments that expand on a point made in the text, define advanced terminology or present data. 

For example, you might find a statement in a paper such as:

Corresponding Footnote : A corresponding footnote might include:

4. See Smith (2020) for a detailed analysis of the data and trends from the past decade. The study outlines the variables influencing the outcomes.

APA Style footnote example

In this case, the footnote provides additional source information that supports the statement. Unlike a reference list entry, a footnote in APA can provide direct commentary or specific page numbers, contributing to a more detailed or specific discussion.

Chicago Style

This style is the king of footnotes! The Chicago Manual of Style is widely used in the humanities and historical journals and is distinctive for its extensive use of footnotes for citation purposes. Chicago-style footnotes provide a comprehensive method for citing sources, enabling detailed commentary and source information directly accessible at the bottom of the page. Footnotes here are used for citing sources and providing additional comments or clarifications related to the text. This style is favored for its precision in citation and the ease with which readers can access source details.

Example in text: Consider a statement in a historical analysis:

Corresponding Footnote : At the bottom of the page, the footnote would appear as:

Abraham Lincoln, Speeches and Writings , 1859-1865 (New York: Library of America, 1989), 234.

Chicago Style footnote example

How should footnotes be written?

Footnotes should be written clearly and concisely. They should provide the necessary information or citation without disrupting the flow of the main text. When writing a footnote, include a superscript number in the text that corresponds to a note at the bottom of the page. The content of the footnote should be directly relevant to the superscript reference, and it should be formatted according to the specific citation style being used (e.g., MLA, APA, Chicago).

How do you format a footnote?

Footnotes are formatted slightly differently depending on the citation style:

  • MLA : Use footnotes for supplementary information or personal commentary, not typically for citations.
  • APA : Similar to MLA, use footnotes for extra information or personal communications.
  • Chicago : Use footnotes extensively for citations, formatting them with full citation details and a period at the end.

Generally, footnotes should start with the corresponding superscript number followed by the text of the footnote. This text should be single-spaced, with a first-line indent, and the same font size as the main text or slightly smaller.

What should a footnote look like?

A typical footnote contains the superscript number that corresponds to the reference in the text, followed by the detailed note or citation. The footnote itself should be at the bottom of the page, separated from the main body of text by a short line or space. It should be short and directly relevant to the reference number.

How do you write the first footnote?

  • Insert a superscript number at the end of the sentence that requires additional information, clarification, or source citation. This number should ideally follow any punctuation (except dashes).
  • Create the corresponding footnote at the bottom of the page. The footnote itself begins with the same superscript number, followed by the content of the note. Ensure it’s clearly separated from the main text, typically by a horizontal line across the column.
  • Format the footnote content according to the guidelines of the citation style you are using. Generally, this includes the source’s author, title, and publication details for citations, or explanatory text for additional information.

What is the easiest footnote format?

The easiest footnote format involves the use of a simple numeric system, as seen in the Chicago Manual of Style. This system is straightforward:

  • Numeric indicators : Use consecutive superscript numbers in the text to indicate footnotes.
  • Footnote details : At the bottom of the page, the same number appears in superscript followed by the footnote content. This content could be as simple as a full citation or a brief explanatory note.

Chicago’s numeric system is straightforward because it consistently uses numbers for footnotes (as opposed to letters or symbols), which makes it easy to track and manage, especially in documents with many references.

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Footnotes in a Paper: How to Use Them Effectively in Your Writing

Discover the best way to use footnotes in a paper. Get expert tips on how to efficiently and effectively use footnotes in academic papers.

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Footnotes in a paper can be a valuable tool in providing a way to supplement our writing with additional information, citations, and explanations without disrupting the flow of the main text. However, many writers may be unsure of when and how to use footnotes effectively. In this article, we will explore the importance and usage of footnotes in academic writing, and provide practical tips for incorporating footnotes into your own writing. Whether you are a seasoned academic writer or just starting out, understanding how to use footnotes can help you increase the clarity and credibility of your writing.

What Are Footnotes?

Footnotes are a useful tool in academic writing that allows for the inclusion of additional information or comments in a document or text. Typically denoted by a small number or symbol in the main text, footnotes in a paper appear at the bottom of the page and can serve a variety of purposes. For example, footnotes can be used to clarify a point, provide background information, or give credit to a source that is not directly quoted or referenced in the main text. They are also helpful in avoiding disruptions to the flow of the main text, particularly when lengthy citations or explanations are required. In short, footnotes provide readers with additional information or references related to specific sections of the text, making them a valuable tool for researchers.

footnotes in a paper

How to Write a Footnote

To write a footnote for a paper, follow these general steps:

  • Determine what information needs to be included in the footnote. This may include the author’s name, the title of the source, the publication date, the publisher, and the page number(s) you are referencing.
  • Place the footnote number or symbol at the end of the sentence or clause that requires the footnote. The footnote number or symbol should be placed after the punctuation, such as a period or comma.
  • Write the footnote itself at the bottom of the page. The first line of the footnote should be indented, and the subsequent lines should be flush with the left margin.
  • Format the footnote according to the citation style you are using (e.g. MLA, APA , Chicago). Each citation style has specific rules for how footnotes should be formatted, so consult the appropriate style guide for details.
  • If you are using a word processing program, such as Microsoft Word, you can use the “Insert Footnote” function to automatically insert footnotes and format them correctly.

Difference Between Footnotes and Endnotes

The main difference between footnotes and endnotes is their placement within a document. Footnotes appear at the bottom of the page on which they are referenced, while endnotes appear at the end of a document, chapter, or section.

Here are some other differences between footnotes and endnotes:

DefinitionNotes placed at the bottom of the same page as the reference.Notes placed at the end of the document.
PlacementBelow the text they reference, usually in smaller font sizes.At the end of the document, usually in the same font size as the main text.
UsageUsed to provide additional information or explanation of a point in the text.Used to provide additional information, explanation, or citation of a source.
AdvantagesEasy to locate and read in the context of the text.Keep the text clean and uncluttered.
DisadvantagesMay clutter the page and distract the reader.May require the reader to flip back and forth between the text and the endnotes.

Chicago Style Footnotes

Chicago-style footnotes are a common citation style used in research papers. In this format, footnotes are used to provide information about a source within the text. There are two types of Chicago-style footnotes: short form and long form. Short form citations include only the basic details of a source if a full bibliography is provided, while long form citations include a full citation the first time a source is cited, with subsequent citations using the short form. 

Here is an example of a Chicago-style footnote using the short form:

“The concept of social capital has been widely discussed in recent years, with Putnam’s Bowling Alone¹ being one of the most influential works in the field.” At the bottom of the page, the corresponding footnote would appear as: ¹ Putnam, Bowling Alone, 26.

Note that the author’s last name is listed first, followed by the abbreviated title of the work (in this case, “Bowling Alone”), and the page number where the information was found.

Here is a Chicago-style footnote using the short form example:

First reference: John Smith, The History of Chicago (Chicago: University of Chicago Press, 2005), 25. Subsequent reference: Smith, The History of Chicago, 30.

Here is an example of a Chicago footnote in text:

“According to Smith, the notion of human rights can be traced back to ancient Greek philosophy.¹”² Bottom of page: ¹John Smith, The Origins of Human Rights (New York: Oxford University Press, 2021), 15. ²Smith, Origins of Human Rights, 22.

Learn how to make citations in Chicago style in our blog “ Chicago Style Citation Made Easy: Formatting and Examples “.

APA Style Footnotes

APA format generally uses parenthetical in-text citations instead of footnotes. However, there are two exceptions to this rule: content footnotes and copyright attribution. Content footnotes provide additional information on a single topic that does not fit coherently in the text, while copyright attribution footnotes are used when a writer uses a lengthy quotation or other copyrighted material, such as a stock photograph. Footnotes are formatted similarly to Chicago style, with sequential superscript numbers coming after the passage and the corresponding footnote at the bottom of the page.

Here’s an example of an APA-style footnote for supplementary information:

In-text: According to recent studies, the COVID-19 vaccine is highly effective in preventing infection and transmission of the virus.¹ Footnote: ¹For more information on the studies cited, see Smith et al. (2021) and Jones et al. (2022).

Learn how to make citations in APA style in our blog “ How to Make Citations using APA Formatting: A Guide “.

MLA Style Footnotes

MLA (Modern Language Association) style does not typically use footnotes. Instead, in-text citations are used to indicate the source of information or quotations. However, if footnotes are required for a specific publication or assignment, the following guidelines can be followed:

Placement: Footnotes should be placed at the bottom of the page on which the reference appears.

Numbering: Footnotes should be numbered consecutively throughout the paper using Arabic numerals. The number should be placed after any punctuation marks, such as periods or commas.

Formatting: Footnotes should be single-spaced and in a smaller font size than the main text.

Content: Footnotes should include bibliographic information for the source being cited, as well as any additional information necessary to clarify the reference. For example, a footnote for a book might include the author, title, publisher, and year of publication, while a footnote for a website might include the URL and date of access.

Example of MLA Style Footnote for a book:

John Doe, The History of Art (New York: Penguin Books, 2000), 24. Example of MLA Style Footnote for a website: “The Benefits of Exercise,” National Institutes of Health, accessed May 15, 2023, https://www.nih.gov/health-information/benefits-exercise .

A MLA Style footnote text example:

Text: According to a recent study, the use of social media can have negative effects on mental health (Johnson 36).² Footnote citation: ² Johnson, Sarah. “The Impact of Social Media on Mental Health.” Journal of Health Psychology, vol. 22, no. 1, 2018, pp. 35-44.

Learn how to make citations in MLA style in our blog “ A Writer’s Guide to MLA Format: How to Get It Right “.

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Footnotes and Endnotes

How to create footnotes or endnotes in chicago style.

  • How do I create a footnote or endnote?
  • How is a footnote different from an endnote?
  • What do I include in the footnote or endnote?

How do I Create a Footnote or Endnote?

Using footnotes or endnotes involves placing a superscript number at the end of a sentence with information (paraphrase, quotation or data) that you wish to cite. The superscript numbers should generally be placed at the end of the sentence to which they refer. They should be placed after any punctuation marks except for the dash.

Footnotes/endnotes begin with 1 and are numbered consecutively throughout the entire essay. You can use MS Word or other software to create footnotes and endnotes.

How is a Footnote different from an Endnote?

 A superscript number refers to a footnote or endnote which contains all of the publishing information and the page number for the information referenced.

  • Footnotes appear on the bottom of the page that contains the sentence to which it refers.
  • Endnotes are listed at the end of the paper on separate pages. On the top of the first page, the title “Notes” is centered one inch from the top of the page. Endnote pages are placed before the bibliography.

Many professors prefer footnotes to endnotes. Check with your professors to see which style they prefer.

What do I Include in the Footnote or Endnote?

The format for a footnote or endnote varies depending on whether it refers to a book, article, or online source. There are some key characteristics common to all footnotes and endnotes:

  • The footnote/endnote begins with the same superscript number as the one that appears in the paper and is followed by a period.
  • Footnotes/endnotes always include a specific page number or numbers where the cited information can be found.
  • The first footnote/endnote to a source provides the full publishing information.

For example:

1. Carolyn Kay,  Art and the German Bourgeoisie:  Alfred Lichtwark and Modern Painting in Hamburg, 1886-1914  (Toronto: University of Toronto Press, 2002), 100.

Subsequent footnote/endnotes for the same source are shortened to provide only the author’s last name, short title, and page number. For example:

2. Kay,  Art and the German Bourgeoisie , 51.

3. Kay, Art and the German Bourgeoisie, 87.

Note that The Chicago Manual of Style (17th ed.) no longer recommends the use of "ibid." for footnote/endnotes that cite the same source as the note immediately preceding it. The shortened citation shown above (author surname, shortened title, page number) is preferred.

Citing different types of sources

The information you include in a footnote varies based on the type of source you cite; navigate to the following pages to learn more:

  • Periodicals
  • Sections of Books
  • Digital Media
  • Other Sources
  • Primary Sources
  • Citing a source (that you have not read) that is Cited in Another Source

Key Elements to Notice

  • In footnotes, information is separated by commas, while in the bibliography, it is separated by periods.
  • In footnotes, the author's first name is listed first, while in the bibliography, the author's last name is listed first.
  • The titles of books and journals are put in italics.
  • The titles of articles are put in quotation marks.
  • All key words in titles are capitalized.
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Endnote Note citing a particular source or making a brief explanatory comment placed at the end of a research paper and arranged sequentially in relation to where the reference appears in the paper.

Footnote Note citing a particular source or making a brief explanatory comment placed at the bottom of a page corresponding to the item cited in the corresponding text above.

Fiske, Robert Hartwell. To the Point: A Dictionary of Concise Writing . New York: W.W. Norton and Company, 2014.

Structure and Writing Style

Advantages of Using Endnotes

  • Endnotes are less distracting to the reader and allows the narrative to flow better.
  • Endnotes don't clutter up the page.
  • As a separate section of a research paper, endnotes allow the reader to read and contemplate all the notes at once.

Disadvantages of Using Endnotes

  • If you want to look at the text of a particular endnote, you have to flip to the end of the research paper to find the information.
  • Depending on how they are created [i.e., continuous numbering or numbers that start over for each chapter], you may have to remember the chapter number as well as the endnote number in order to find the correct one.
  • Endnotes may carry a negative connotation much like the proverbial "fine print" or hidden disclaimers in advertising. A reader may believe you are trying to hide something by burying it in a hard-to-find endnote.

Advantages of Using Footnotes

  • Readers interested in identifying the source or note can quickly glance down the page to find what they are looking for.
  • It allows the reader to immediately link the footnote to the subject of the text without having to take the time to find the note at the back of the paper.
  • Footnotes are automatically included when printing off specific pages.

Disadvantages of Using Footnotes

  • Footnotes can clutter up the page and, thus, negatively impact the overall look of the page.
  • If there are multiple columns, charts, or tables below only a small segment of text that includes a footnote, then you must decide where the footnotes should appear.
  • If the footnotes are lengthy, there's a risk they could dominate the page, although this issue is considered acceptable in legal scholarship.
  • Adding lengthy footnotes after the paper has been completed can alter the page where other sources are located [i.e., a long footnote can push text to the next page].
  • It is more difficult learning how to insert footnotes using your word processing program than simply adding endnotes at the end of your paper.

Things to keep in mind when considering using either endnotes or footnotes in your research paper :

1.    Footnotes are numbered consecutively throughout a research paper, except for those notes accompanying special material (e.g., figures, tables, charts, etc.). Numbering of footnotes are "superscript"--Arabic numbers typed slightly above the line of text. Do not include periods, parentheses, or slashes. They can follow all punctuation marks except dashes. In general, to avoid interrupting the continuity of the text, footnote numbers are placed at the end of the sentence, clause, or phrase containing the quoted or paraphrased material. 2.    Depending on the writing style used in your class, endnotes may take the place of a list of resources cited in your paper or they may represent non-bibliographic items, such as comments or observations, followed by a separate list of references to the sources you cited and arranged alphabetically by the author's last name. If you are unsure about how to use endnotes, consult with your professor. 3.    In general, the use of footnotes in most academic writing is now considered a bit outdated and has been replaced by endnotes, which are much easier to place in your paper, even with the advent of word processing programs. However, some disciplines, such as law and history, still predominantly utilize footnotes. Consult with your professor about which form to use and always remember that, whichever style of citation you choose, apply it consistently throughout your paper.

NOTE:   Always think critically about the information you place in a footnote or endnote. Ask yourself, is this supplementary or tangential information that would otherwise disrupt the narrative flow of the text or is this essential information that I should integrate into the main text? If you are not sure, it's better to work it into the text. Too many notes implies a disorganized paper.

Cermak, Bonni and Jennifer Troxell. A Guide to Footnotes and Endnotes for NASA History Authors . NASA History Program. History Division; Hale, Ali. Should You Use Footnotes or Endnotes? DailyWritingTips.com; Tables, Appendices, Footnotes and Endnotes. The Writing Lab and The OWL. Purdue University; Lunsford, Andrea A. and Robert Connors. The St. Martin's Handbook . New York: St. Martin's Press, 1989; Saller, Carol. “Endnotes or Footnotes? Some Considerations.” The Chronicle of Higher Education 58 (January 6, 2012): http://chronicle.com/blogs/linguafranca/2012/01/06/endnotes-or-footnotes-some-considerations/.

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what are footnotes

What are Footnotes and How to Use Them for Research?

The research process is inherently collaborative, involving the analysis of the collective body of knowledge developed over time. It is academically and ethically vital to acknowledge others’ contributions. Footnotes serve as subtle markers of acknowledgment while also providing supplementary details to enhance the reader’s understanding and engagement with your work. 

Table of Contents

What are footnotes?   

During your research, you’ll encounter inconspicuous superscript numbers at the end of some sentences, which link to corresponding notes at the page’s bottom or ‘foot.’ These notes serve as references to cited works and offer supplementary information to aid the reader’s understanding.  

It’s important to note that not all references and supplementary notes are at the bottom of the page; some are placed at the end of the research paper as “endnotes.” This doesn’t lessen their significance; they still offer valuable context and insights. 

Footnotes vs Endnotes  

Footnotes and endnotes fulfill the same fundamental purpose in scholarly writing. However, the choice between them often reflects an author’s personal preference or aligns with specific style guidelines. Footnotes are frequently utilized for immediate comments or explanations related to the main text. On the other hand, endnotes are commonly reserved for citations of the works referenced within the text.  

Let’s examine footnotes and endnotes more closely to understand the distinctions between these two citation methods: 

Footnotes are highly effective due to their ease of access and their ability to direct readers to relevant citations or supplementary ideas swiftly. This approach increases the likelihood that readers will engage with the citation or additional information. However, the limited space at the bottom of the page necessitates caution. Overloading it with excessive other text can be overwhelming and potentially distracting for readers.  

Endnotes, in contrast, offer the advantage of being located at the end of a paper within a designated section, giving authors the freedom to incorporate supplementary information liberally without the need to use up the limited space on a page. However, endnotes are often overlooked by readers. This oversight can be attributed to a mental justification that if information is not included in the main text, it may not hold significant value.¹²

Footnote Citation Styles  

Incorporating footnotes into your research paper is crucial, but it’s equally important to grasp the specific footnote citation style required by your target journal or publication. The format and style of footnote citations can differ significantly based on the citation style guide in use. Below, you’ll find illustrative examples of how to use footnotes in essays according to the central style guides:¹

Chicago Style  

The Chicago Style uses footnotes to provide full source details in the form of numbered notes at the bottom of each page. A corresponding bibliography is provided at the end of the research essay or document. Here is an example: 

“The Apollo program was designed by men, for men. If we do not acknowledge the gender bias of the early space program, it becomes difficult to move past it.” ¹ 

1.1 Mary Robinette Kowal, To Make It to the Moon, Women Have to Escape Earth’s Gender Bias (New York Times, 17 July 1969). 

In this example, the superscript “1” in the text corresponds to the first footnote, which provides complete source information for an article by Mary Robinette Kowal in The New York Times. 

Modern Language Association (MLA) Style

The MLA Style does not typically use footnotes for citations. Instead, it relies on in-text citations with an author-page number format. However, the footnotes might be utilized for explanatory or supplementary information. Example: 

“The protagonist’s transformation throughout the novel is central to its theme and character development.” 1 

1 This analysis draws on the ideas of literary critic John Smith regarding character evolution in narrative fiction. 

In this example, the superscript “1” in the main text points to a footnote that offers additional context and acknowledges the source, i.e., John Smith’s ideas. 

American Psychological Association (APA) Style

APA Style typically uses in-text citations rather than footnotes. However, you may use footnotes for clarifications or additional information, not for standard source citations. Here is an example: 

“The study’s results revealed a statistically significant correlation between the two variables^1^.” 

^1^ Note that the p-value was set at 0.05 as the threshold for statistical significance. 

In the example, the superscript “^1^” in the main text indicates a footnote, which is used to provide a brief explanation. 

How to add Footnotes in Microsoft Word and Google Docs?  

So, how do you make footnotes? Adding footnotes in both Microsoft Word and Google Docs is a straightforward process. Step-by-step instructions are provided below for adding footnotes in both applications: 

Microsoft Word  

  • Position your cursor where you want to insert a footnote in the document. 
  • Navigate to the “References” tab and click on the “Insert Footnote” button. 
  • A small superscript number (typically “1”) will appear where you positioned the cursor, and a corresponding footnote area will appear at the bottom of the page. Enter your footnote content in this designated area. 
  • To insert additional footnotes, repeat the same steps. Microsoft Word will automatically manage the numbering of footnotes. (4) 

Google Docs  

  • Place the cursor at the location where you wish to insert a footnote. 
  • In the menu bar, click on “Insert” and select “Footnote.” 
  • A superscript number (usually “1”) will appear where you placed your cursor, and a footnote section will be created at the bottom of the page. Type your footnote content in this section. 
  • Add more footnotes using the same steps. Google Docs will handle the footnotes numbering. (5) 

References:  

  • Footnotes and Endnotes  – Khalifa University 
  • Footnotes and Endnotes  – University of Bristol 
  • Footnote Referencing Styles  – Bibliography.com 
  • Add footnotes and endnotes  – Microsoft Support 
  • Use headers, footers, page numbers, & footnotes – Google Docs Editors Help 

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How to Use Footnotes and Endnotes in Essays

  • 4-minute read
  • 23rd February 2019

Footnotes and endnotes both offer a way to add extra information to an essay . But what should you include in footnotes and endnotes? And when should you use them? In this post, we run through everything you need to know about using footnotes and endnotes in essays.

What Are Footnotes and Endnotes?

Footnotes appear at the bottom or ‘foot’ of the page. This lets you add information to an essay without interrupting the flow of the main text. Usually, this will be a citation or non-essential commentary.

To indicate a footnote, you will need to add a superscript number to the text, such as at the end of this sentence. 1 These numbers then correspond to numbered notes at the bottom of the page.

Example footnotes.

Endnotes are like footnotes, but they appear together at the end of the document rather than at the bottom of individual pages. This means endnotes are less immediately accessible for the reader than footnotes, but it helps ensure that pages with multiple notes don’t become cluttered. If you are not sure which to use, check your university style guide for advice.

Footnotes and Endnotes in Microsoft Word

To insert a footnote or endnote in a Microsoft Word document, you need to:

  • Go to References > Footnotes on the main ribbon
  • Select either Insert Footnote or Insert Endnote as required
  • Type your note in the newly created footnote/endnote

Footnote options.

You can also customise the style of footnotes and endnotes by clicking on the little arrow in the bottom right of the Footnotes section of the References tab (or by going to Insert > Footnotes in Word for Mac ). This will open a new window where you can select your preferred formatting options.

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When to Use Footnotes and Endnotes

The main uses of footnotes and endnotes are as follows:

  • To add a footnote citation in referencing systems such as MHRA and Chicago , with full source information also given in a bibliography at the end of the document. Endnotes are also used for citations in some systems, such as in IEEE or Vancouver referencing, where numbers in the text point to an entry in a reference list at the end of the document.
  • To add non-essential commentary on something in the main text of your document. For example, if your research has raised a question that is not directly relevant to your essay, you may want to mention it in a footnote or endnote instead. This lets you acknowledge it in your work – showing the reader that you haven’t simply ignored it or failed to notice something – but without interrupting the flow of the main document.

Keep in mind, too, that some referencing systems use in-text parenthetical citations . As such, you should only give references in footnotes or endnotes if your university has asked you to do this.

Do They Count Towards the Word Limit?

We’re often asked whether to include footnotes and endnotes in the word count for an essay. Different universities have different rules about this, so you will have to check your style guide . However, you should never use footnotes or endnotes to try and cheat the word count.

The key here is that only non-essential information should go in footnotes or endnotes. As such, if you move vital evidence or analysis to a footnote, the person marking your work may ignore it. And reducing the word count is never more important than putting forward a full, coherent argument.

If you do need to reduce the word count in an essay, you have other options, such as rewriting wordy sentences or cutting repetition. Having your work proofread is a great way to ensure that your writing is always clear and concise, too, so let us know if you’d like any help.

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What Are They

Footnotes are short numbered notes that are placed at the bottom of the page in an essay or article. They are used for a variety of reasons including, citing materials, providing notes on a source or topic, and to acknowledge copyright status. 

Although you will find footnotes in many journal articles, they are not typically required in APA or MLA formatted essays. They are most heavily used when applying the CMOS style. 

For information on footnotes in the  Publication Manual of the American Psychological Association  see section 2.13 "Footnotes.". For information on using footnotes with MLA see the " Using Notes in MLA Style " article from the MLA Style Center .  For information on footnotes in  The Chicago Manual of Style  see Chapter 14 "Notes and Bibliography."

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Footnotes, endnotes, and citations

What citations should I use in my essay?

Regular essays and timed exams

Most instructors at the undergraduate level (including instructors on law conversion courses) do not require students to do more than indicate the names of cases or statutes in the text of their essays and examinations, particularly in timed examinations. While it's preferable to give the full case name (such as Jones v Smith), in a timed examination you can get by with one name or the other. Usually people pick the first party's name, unless it's a very common name or a criminal case. Sometimes, though, you will notice that your textbook or lecturer uses the second party's name regularly. If you know that the case is commonly short-cited to the second party's name, go ahead and use that.

If you can't remember the name of a particular case or statute, simply describe it. For example, 'the snail in the bottle case' sufficiently evokes Donoghue v. Stevenson . 'The first Occupiers' Liability Act' gets you past worries about the particular year it was enacted. Of course, if you are working on a weekly essay or a long-term research project you must take the trouble of finding and putting in the proper title or citation.

Once you have used the full name once, feel free to use a short citation, such as ' Donoghue' or 'the 1984 Act.' There's no need to keep repeating the full name.

If you are writing your essay by hand, there is no need to use different coloured ink for a case or statutory citation. It often helps if you underline case names, but you won't lose points if you don't. If you are typing your essay, you can underline or italicise case names, but there's no need for elaborate type faces. Make your writing stand out rather than your design skills. Sometimes it seems that students spend more time formatting the essay than they do writing it. Don't be one of those students.

Typically, citations in a regular essay or timed examination are placed in the text next to the proposition they support. See the sample student essays in chapter 10 of the book for models.

These suggestions are only guidelines to use if you do not receive more specific instructions from your tutor or lecturer. If your university or instructors have particular rules that they wish you to follow, do so.

Long-term research essays and theses

If you are doing a long-term research project, you should use the full and proper citation, either in a footnote, an endnote or in the text. Again, once you have given the citation in full, you may use the appropriate short citation.

Very often, instructors will give formatting advice for long-term research essays. Certainly students doing masters theses will be given detailed information on the citation convention they are to use. If you have not been given any guidance, ask for it. Also, don't wait until the last minute to investigate your citation requirements. There's nothing worse than having to go back through all your research to add in specific page numbers or dates because you forgot to do it the first time. With a long-term project, you can and should plan ahead.

When should I quote and when should I paraphrase?

As mentioned in the book, quotes are good in the law. The words of Lord Justice Whozits are much more persuasive than a mere lawyer's. Use quotations freely, as long as you:

  • use the exact words and punctuation found in the original source;
  • use square brackets [ ] to indicate changes in capitalization, punctuation and language; and
  • provide the source of the quotation.

Remember also that extensive quotations from statutes – particularly if you are permitted to use the statute book in an otherwise closed examination – are not particularly impressive. What is more important in those situations is your interpretation and use of the statute.

Never include the precise language of a source – or language that is virtually identical – without a proper attribution. Not only does that constitute plagiarism, it is counter to the use of source material in law. The law depends on published precedent for its authority. A legal principle is only as good as its source. Therefore, you want to demonstrate where your various propositions come from, since they will be more valuable if they come from an outside source.

However, there are times when you should paraphrase rather than provide a direct quotation. If the pertinent section is very long or discusses issues that are not relevant to the point you are making, then go ahead and paraphrase. Similarly, if the point you are making is only tangential to your larger argument, a paraphrase may be appropriate. Sometimes it's wise to save your ammunition for the big issues.

If you are paraphrasing someone, it is still helpful to identify the source so that your reader knows that you are not making the proposition up out of whole cloth. Again, lawyers and judges evaluate the strength of your argument based on the strength of your sources. Show your reader how well-read you are and earn every point you possibly can.

When should I use footnotes, when should I use endnotes and when should I put the citation in the text?

For the most part, undergraduates can put their citations in the text of their essays. The citation can be set off mid-sentence through parenthesis ( Hansel v Gretel ) or can follow the sentence. Hansel v Gretel . The one exception for undergraduates is on long-term research projects, where the instructors might ask for footnotes or endnotes.

There is no formal convention on when you should use footnotes rather than endnotes. For the most part, it's a matter of style and personal choice, although the choice may not be yours to make. If you are writing a postgraduate thesis or dissertation, your faculty or your supervisor may have very strict ideas on how the work is to be presented. Follow those rules to the letter. Similarly, if you are hoping to have your work published in a periodical or legal journal, ask to see the editorial guidelines. An editor is much more likely to accept your work if it conforms to the house style.

If the issue is left entirely up to you, then you simply need to decide which form of notes you find more helpful. Footnotes can be seen to break the flow of the text, but they also help the reader follow the argument, particularly if the text is comparing and contrasting different sources. Footnotes are also more useful than endnotes if the footnotes contain substantive information rather than simply providing source material. For the most part, British and European writers do not include anything in their foot- or endnotes other than the citations themselves, possibly with a “see also” reference to additional material. American authors, on the other hand, fill their footnotes with additional substantive information. Often the best information in an American law review article can be found in the footnotes.

American legal texts are also known for dropping a footnote at the end of almost every sentence, whereas texts from other countries do so much less, usually only following a direct quote. The reason why American journals use as many footnotes as they do is because most American law journals are edited by law students. British and European journals are peer-reviewed, meaning that an article is only accepted if it passes muster with other academics and/or practitioners. Therefore, the text of the article is verified before it is accepted for publication. American students are not experts in their fields, so they must – and do – check the substance of each and every footnote by hand to make sure that it supports the proposition stated. Therefore, American law journals contain excellent source material for researchers, since the footnotes point the reader to a wide variety of verified information and additional resources. Because American footnotes contain so much information, it makes sense to place them on the same page as the text they support rather than at the end of the article or book.

If you are writing for a non-American audience, you should strongly consider putting citations only into your notes. Once you have made that decision, it matters less whether you put the note on the page or at the end of the piece. If you have a multi-chaptered work (such as a book or doctoral dissertation), then you might consider putting the notes at the end of each chapter rather than at the end of the work as a whole. However, it is highly unlikely that the decision to use footnotes or endnotes will be left to your discretion if you are writing a book or dissertation. Again, conform your text to the guidelines of your institution.

Do remember your punctuation, however. Footnotes and endnotes should both end with a full stop.

What is 'proper' citation form?

If you are an undergraduate writing a weekly essay or timed examination, a case name or the short title of a statute should be sufficient, unless you are told otherwise. If you are writing a more elaborate work, you should follow proper citation guidelines.

There are entire books written on how to cite legal authorities. If you are writing a detailed research paper such as a thesis or dissertation, you should consult one of those books so that you cite your sources properly. Your law librarian can help you find those resources. Also, you should know that each jurisdiction has its own conventions on how to cite legal authorities, so the style of case citation, for example, may not appear consistent if you are citing materials from different countries, even if the individual citations are correct.

In the U.K., authors generally do not give parallel (i.e., multiple) citations except when citing both a neutral reporter and an official reporter, though they must follow strict rules regarding punctuation (or the lack thereof), the type of brackets, typeface, etc. Examples of common British case citations are as follows.

Walker v Sitter [2004] EWHC 1000 (Ch) [5]-[7] (neutral citation, pinpointing paragraphs 5 to 7)

Yin v Yang [2004] QB 123 (QB) at 125 (Schmidt, J) (pinpointing page, noting author)

Tweedledee v Tweedledum [2003] 2 All ER 456 (HL)

Re Luftborough Airport [2002] 1 WLR 89 (Com Ct)

Barking Mad Ltd v Crazy Horse Int'l Inc (2005) Times, 15 April (QB)

The neutral citation system was introduced in the U.K. in January 2001. All cases since then have a neutral citation as well as numbered paragraphs instead of page numbers. The abbreviations indicate which court heard the case. For example, the jurisdictions include:

UK United Kingdom (used only with House of Lords decisions)

EW England and Wales

Scot Scotland

NI Northern Ireland

The court abbreviations which follow the jurisdictional abbreviation in a neutral citation are:

HL House of Lords

CA Civ Court of Appeal (Civil Division)

CA Crim Court of Appeal (Criminal Division)

HC (Ch) High Court (Chancery Division)

HC (QB) High Court (Queen's Bench)

HC (Admin) High Court (Administrative Court Division)

HC (Fam) High Court (Family Division)

HC (Pat) Patents Court

HC (Comm) Commercial Court

HC (Admlty) Admiralty Court

HC (TCC) Technology & Construction Court

European jurisprudence follows its own conventions. You might see citations along the following lines:

Case 26/97 Commission v. Ireland [1999] ECR 321

Case 177/75 Belgium v. Spain [1976] ECR 722, para. 3

Case C-123/92P Y v Commission [1994] ECR I-4321

American legal citations follow a different format, using the style known as the 'Bluebook', which is a citation guide put out by the Harvard Law Review. You'll usually see citations similar to the following:

Darth Vader v Skywalker , 103 F.3d 1049 (2d Cir. 2005)

In re Ballyhoo , 998 F.Supp. 22 (D. D.C. 1999)

Grasshopper v The Ant , 37 App. 2d 24 (Ill. App. Div. 2003)

Cowboy v Cow , 42 S.W.3d 444 (Tex. 2004)

Many common words (railway, limited, public limited company) can be abbreviated in a case name. Those abbreviations can be found in citation guides such as OSCOLA, which is described below. Similarly, many reporting series are known by their abbreviations. Some of the more common British reporters follow, with their short titles. Be aware that some of these series may also have numbers appearing before the volume name (for example, 2 QB).

Official Law Reports AC, QB, Ch, Fam, P

Weekly Law Reports WLR

European Court Reports ECR

All England Law Reports All ER, All ER Com

Common Market Law Reports CMLR

Criminal Appeal Reports Cr App R

Family Law Reports FLR

Lloyd's Law Reports Lloyd's Rep

Official Journal of the EC OJ

Scots Law Times CLT

The Times The Times

Citation of statutes in the U.K. is a straightforward affair. Typically a student needs only cite the name of the legislation and the year, along with the appropriate section, chapter or paragraph number. For example:

Companies Act 1985, sch. 1, para. 3

Arbitration Act 1996, s. 69

European legislation is equally simple, though the titles are often longer and appear in lower case.

Council Regulation (EC) 2693/94 addressing the need to conform widget size in automobiles [1994] OJ L123

Directive 77/331 applying competition rules to the dairy industry [1977] OJ L78/41

When citing American federal legislation and rules, do not include the name of the enactment.

28 U.S.C. § 1391

Fed. R. Civ. P. 4

Students should be aware that two well-known U.S. treatise series – the Restatement (of Tort, of Contract, of Foreign Relations, etc.) and A.L.R. (American Law Reports) do not constitute binding authority in the U.S. Instead, these works simply generalise about the laws of the various U.S. states and should not be considered as authoritative in any particular jurisdiction. While some courts may adopt the Restatement position on a particular issue, the Restatement does not constitute the law in that jurisdiction until a court has so stated. In all instances, the authority comes from the court, not the Restatement.

Which reporting series should I use?

Since the introduction of the neutral citation system in 2001, it is always proper to cite to that series, using paragraph numbers instead of page numbers. If a case is reported in the official Law Reports (AC, QB, etc.), then you should use that report in addition to the neutral citation (at least for decisions after 2001). If the case is not reported in the official Law Reports, you should use to the Weekly Law Reports and All England Law Reports, in that order. After that, you may turn to any other published source, including specialist series such as Lloyd's or the Times.

What is OSCOLA and how does it relate to the Harvard citation style?

'OSCOLA' refers to the Oxford Standard Citation of Legal Authorities, which is available free of charge on the University of Oxford Faculty of Law website ( www.law.ox.ac.uk ). The faculty releases two publications: 'Big OSCOLA', which is over 300 pages in length, and 'Little OSCOLA', which is about 30 pages long. Both documents give you detailed instructions on how to cite cases, statutes, books, journals and other legal materials. Most people should start with Little OSCOLA unless they are doing a postgraduate degree at Oxford or are directed to use Big OSCOLA. The OSCOLA system reflects a common understanding of how British legal authorities should be cited and is a good place to learn how British and European cases should be referenced. Notably, the OSCOLA system proposes a citation methodology that conflicts with American usage, and those whose work includes a large number of American cases may prefer to consult the latest edition of the Bluebook, which is available in many university law libraries, for U.S. sources.

You may also hear about the Harvard style of citation, particularly if you conduct socio-legal or other multi-disciplinary research. The Harvard style is not the same as the Bluebook, even though that guide is also put out by Harvard. The Harvard style of citation focuses primarily on non-legal sources such as books and journal articles, and, as such, is not as useful for those taking a strict law course as OSCOLA is. Under the Harvard style of citation, cases are cited in the text, rather than in the footnotes.

Citation signals

Older sources make wide use of Latin phrases such as infra, supra, ante, id, op cit, loc cit and contra . American sources continue to use many of these phrases in addition to a number of signals ( see, see also, but see, cf., accord ) at the beginning of a cite and descriptors ( cert. denied , aff'd by, rev'd by, superseded by , etc.) following a cite. Current British usage avoids all Latin phrases except for ibid , which means 'in the place of' and refers to the preceding citation only. You may only use ibid if the subsequent citation is to the same page; otherwise, use ibid 345 (if, for example, the new citation is to page number 345) or ibid art. 3 (if, for example, the new citation is to article 3). You may also use cf (compare) as a signal, but avoid the American use of see, see also, but see , etc.

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Footnote/Endnote

Author First M. Last Name, "Chapter or Essay Title," in  Book Title , ed. First M. Last Name (Place of Publication: Publisher, date), page cited.

Short version: Author Last Name, "Chapter or Essay Title (shortened if necessary)," page cited.

Bibliography

Author Last Name, First M.   "Chapter or Essay Title."  In  Book Title ,   edited by First M. Last Name,  page range.   Place of Publication: Publisher, date.

Eric Charry, "Music and Islam in Sub-Saharan Africa," in  The History of Islam in Africa , eds. Nehwmia Levtzion and Randall L. Pouwels  (Athens, OH: Ohio University Press, 2000), 550.

Short version: Charry, "Music and Islam in Sub-Saharan Africa," 550.

Charry, Eric.   "Music and Islam in Sub-Saharan Africa."  In  The History of Islam in Africa ,   edited by Nehwmia Levtzion and Randall L. Pouwels,   545-573.   Athens, OH: Ohio  University Press, 2000.

Alan Liu, "Where is Cultural Criticism in the Digital Humanities?," in  Debates in the Digital Humanities , ed. Matthew K. Gold (Minneapolis: University of Minnesota Press, 2013), accessed January 23, 2014,  http://dhdebates.gc.cuny.edu/debates/text/20. 

Short version: Liu, "Where is Cultural Criticism."

Liu, Alan.  "Where is Cultural Criticism in the Digital Humanities?."   In  Debates in the Digital Humanities ,   edited by Matthew K. Gold.   Minneapolis: University of Minnesota Press, 2013.   A ccessed January 23, 2014.   http://dhdebates.gc.cuny.edu/debates/text/20. 

Strobe Talbott, foreword to   Beyond Tianamen: The Politics of U.S.-China Relations 1989-2000 , by Robert L. Suettinger (Washington, D. C.: Brookings Institute Press, 2003), x.

Short version: Talbott, foreword, x.

Talbott, Strobe.   Foreword to   Beyond Tianamen: The Politics of U.S.-China Relations 1989-2000 ,   by Robert L. Suettinger,  ix-x.   Washington, D. C.: Brookings Institute  Press, 2003.

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What Are Endnotes? | Guide with Examples

Published on March 29, 2022 by Jack Caulfield . Revised on June 7, 2022.

Endnotes are notes that appear at the end of your text in a piece of academic writing. They’re indicated in the text with numbers (or occasionally other symbols). Endnotes are used:

  • For citations in certain styles
  • To add extra information that doesn’t fit smoothly into the main text

What Are Endnotes

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Table of contents

Endnotes vs. footnotes, how to use endnotes, endnotes in chicago style, endnotes in apa style, endnotes in mla style, how to insert endnotes in word, frequently asked questions about footnotes and endnotes.

Endnotes are sometimes confused with footnotes . Footnotes are also used to provide citations and/or supplementary information, but they appear at the bottom of the relevant page instead of all together at the end.

  • Clutter your writing less than footnotes, since they’re all grouped together instead of spread throughout the text
  • Are less convenient, since the reader has to flip to the back to read the notes
  • Are convenient, since the reader finds the additional information on the same page as the relevant part of the text
  • Can make your text appear messy, especially if there are a lot of them

You should usually choose either footnotes or endnotes and use them consistently. Your instructor may tell you which style of note to use.

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Endnote numbers appear at the end of the clause or sentence the endnote relates to. The number appears after any punctuation, unless the clause ends with an em dash, in which case it appears before it. There’s no space added after the number.

The general consensus now—though there are dissenting voices 1 —is that this experiment was simply too methodologically flawed to produce valid results. 2

Endnotes are numbered consecutively in the order they appear in your text. Each note has a unique number; don’t repeat the same number even if you cite the same source more than once.

In Chicago notes and bibliography style , you use endnotes (or footnotes) for citations. Either kind of note can also be used to add extra information: further examples, commentary on the sources you cite, or more detailed discussion of ideas you mention in the text.

Place your Chicago endnotes at the end of the relevant clause or sentence. A citation endnote provides full information about a source the first time you cite it, and shortened information for any further citations of that source.

                    1. Hanna Pickard, “What Is Personality Disorder?” Philosophy, Psychiatry, & Psychology 18, no. 3 (September 2011): 182. https://doi.org/10.1353/ppp.2011.0040.

          2. Pickard, “What Is Personality Disorder?” 182.

You should still include a full list of your sources in a bibliography after the endnotes, unless you’re writing a very short paper and have been told you don’t need to.

The endnotes page appears just before the bibliography and starts with the title “Notes” written in bold and centered. The notes themselves are formatted as follows:

  • Leave a blank line between endnotes, and single-space the notes themselves.
  • Indent the start of each endnote.
  • Write the note numbers in normal text, not superscript, followed by a period and then a space.

Either endnotes or footnotes may be used in APA Style to provide additional information. They’re not used for citation; for that you’ll use APA in-text citations instead.

APA endnotes are used to provide copyright attributions where necessary. They can also be used, for example, to elaborate on ideas in the text or provide further examples. Do this sparingly, however; APA cautions against adding unnecessary details.

1 Copyright 2022 by Scribbr. Reprinted with permission.

        2 Admittedly, the issue is not as straightforward as this brief summary suggests. See Prakash (2019) for a more in-depth consideration of …

Endnotes appear on a separate page after the reference list , with the heading “Footnotes” (confusingly, APA doesn’t use the term “endnotes”) in bold and centered at the top.

The notes are written as double-spaced indented paragraphs. Start each note with its number, in superscript and followed by a space.

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MLA in-text citations appear in parentheses in the text, but you can use endnotes to avoid cluttering the text if you need a lot of citations in one place.

MLA endnotes may also be used to provide additional information—any necessary clarifications, further examples, or expansions of ideas covered briefly in the text.

      1 See James 35; Lanning 15–25; and Johnson 77.

       2 Other nations, including Italy and France, were undergoing similar political convulsions during the same period.

List your endnotes on a separate page before the Works Cited list, and title them either “Notes” or “Endnotes.” Indent the first line of each endnote, and start the note with the number in superscript followed by a space. Endnotes should be double-spaced.

It’s straightforward to insert endnotes automatically in many word processors, including Microsoft Word. Just follow these steps:

  • Click on the point in the text where you want the endnote number to appear.
  • Open the “References” tab at the top, and click on “Insert Endnote.”
  • Type something in the endnote that appears at the end of your document.

But if you’re following one of the styles covered above, do adjust the formatting to match their requirements and add a heading for the endnotes page.

Footnotes appear at the bottom of the page they refer to. This is convenient for the reader but may cause your text to look cluttered if there are a lot of footnotes.

Endnotes appear all together at the end of the whole text. This may be less convenient for the reader but reduces clutter.

Both footnotes and endnotes are used in the same way: to cite sources or add extra information. You should usually choose one or the other to use in your text, not both.

To insert endnotes in Microsoft Word, follow the steps below:

  • Click on the spot in the text where you want the endnote to show up.
  • In the “References” tab at the top, select “Insert Endnote.”
  • Type whatever text you want into the endnote.

If you need to change the type of notes used in a Word document from footnotes to endnotes , or the other way around, follow these steps:

  • Open the “References” tab, and click the arrow in the bottom-right corner of the “Footnotes” section.
  • In the pop-up window, click on “Convert…”
  • Choose the option you need, and click “OK.”

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ArtI.S1.3.1 Separation of Powers and Checks and Balances

Article I, Section 1:

All legislative Powers herein granted shall be vested in a Congress of the United States, which shall consist of a Senate and House of Representatives.

The Legislative Vesting Clause, along with the coordinate Executive and Judicial Vesting Clauses, delineate the powers the Framers accorded to the National Government 's Legislative, Executive, and Judicial Branches. Separating the powers to legislate, to execute, and to adjudicate into separate government departments was a familiar concept to the Framers. As noted by James Madison in the Federalist No. 47 , political theorist Baron Charles de Montesquieu had written about the separation of powers concept almost 100 years earlier. 1 Footnote The Federalist No. 47 (James Madison) . Consequently, when the colonies separated from Great Britain following the American Revolution, the framers of the new state constitutions generally embraced the principle of separation of powers in their charters. 2 Footnote The Constitution of Virginia of 1776 provided: The legislative, executive, and judiciary department shall be separate and distinct, so that neither exercise the powers properly belonging to the other; nor shall any person exercise the powers of more than one of them, at the same time[.] The Constitution of Virginia of 1776 , reprinted in 10 Sources and Documents of United States Constitutions 52 (William F. Swindler ed., 1979) . See also 5 id. at 96 . Similarly, the Massachusetts Constitution of 1780 provided: In the government of this commonwealth, the legislative department shall never exercise the executive and judicial powers, or either of them; the executive shall never exercise the legislative and judicial powers, or either of them; the judicial shall never exercise the legislative and executive powers, or either of them; to the end it may be a government of laws and not of men. The framers of the new state constitutions, however, did not necessarily incorporate systems of checks and balances. Accordingly, violations of the separation of powers doctrine by state legislatures were commonplace prior to the convening of the Constitutional Convention. 3 Footnote The Federalist No. 51 (James Madison) ( In republican government the legislative authority, necessarily, predominates. ). See also id. No. 48 . This theme continues to influence the Court’s evaluation of congressional initiatives. See, e.g., Metro. Wash. Airports Auth. v. Citizens for the Abatement of Aircraft Noise , 501 U.S. 252, 273–74, 277 (1991) . But compare id. at 286 n.3 (White, J., dissenting). Theory as much as experience guided the Framers in the summer of 1787. 4 Footnote The intellectual history of the Confederation period and the Constitutional Convention is detailed in Gordon S. Wood , The Creation of the American Republic, 1776–1787 (1969) .

In drafting the Constitution, the Framers considered how to order a system of government that provided sufficient power to govern while protecting the liberties of the governed. 5 Footnote See, e.g. , M.J.C. Vile , Constitutionalism and the Separation of Powers (1967) . The doctrine of separation of powers, which the Framers implemented in drafting the Constitution, was based on several generally held principles: the separation of government into three branches: legislative, executive, and judicial; the concept that each branch performs unique and identifiable functions that are appropriate to each branch; and the proscription against any person or group serving in more than one branch simultaneously. 6 Footnote The Federalist No. 47 (James Madison) .

While the Constitution largely effectuated these principles, the Framers’ separation of power was not rigid, but incorporated a system of checks and balances whereby one branch could check the powers assigned to another. For example, the Constitution allows the President to veto legislation, 7 Footnote U.S. Const. art. I, § 7 . but requires the President to gain the Senate’s consent to appoint executive officers and judges or enter into treaties. 8 Footnote Id. art. II, § 2, cl. 2 . Some critics of the proposed Constitution objected to what they regarded as a curious mixture of government functions and powers. 9 Footnote See, e.g. , The Federalist No. 47 (James Madison) ( [O]ne of the principal objections inculcated by the more respectable adversaries to the Constitution, is its supposed violation of the political maxim, that the legislative, executive, and judiciary departments ought to be separate and distinct. . . . The several departments of power are distributed and blended in such a manner as at once to destroy all symmetry and beauty of form, and to expose some of the essential parts of the edifice to the danger of being crushed by the disproportionate weight of other parts. ). In response to criticism that the Constitution blurred the powers accorded to the three branches of government , James Madison wrote a series of essays addressing this issue. 10 Footnote Id. Nos. 47–51 (James Madison) .

In the Federalist No. 47 , Madison relied on the theories of Baron de Montesquieu in addressing critics of the new Constitution. 11 Footnote Id. No. 47 (James Madison) . According to Madison, Montesquieu and other political theorists did not mean that these departments ought to have no partial agency in, or no control over, the acts of each other, but rather liberty was endangered where the whole power of one department is exercised by the same hands which possess the whole power of another department. 12 Footnote Id. Madison further reasoned that neither sharply drawn demarcations of institutional boundaries nor appeals to the electorate were sufficient to protect liberty. 13 Footnote Id. Nos. 47–49 . Instead, to secure liberty from concentrated power, Madison argued, consists in giving to those who administer each department the necessary constitutional means and personal motives to resist encroachments of the others. 14 Footnote Id. No. 51 . Thus, James Madison famously stated: Ambition must be made to counteract ambition. The interest of the man must be connected with the constitutional rights of the place. 15 Footnote Id.

To achieve the principles articulated by Madison in the Federalist No. 47 , the Constitution features many checks and balances. For example, bicameralism reduces legislative predominance, 16 Footnote U.S. Const. art. I, § 1 . while the presidential veto gives the President a means of defending his priorities and preventing congressional overreach. 17 Footnote Id. art. I, § 7 . The Senate’s role in appointments and treaties provides a check on the President. 18 Footnote Id. art. II, § 2, cl. 2 . The courts are assured independence from the political branches through good-behavior tenure and security of compensations, 19 Footnote Id. art. III, § 1 . and, through judicial review, the courts check the other two branches. 20 Footnote Id. ; Marbury v. Madison , 5 U.S. (1 Cranch.) 137 (1803) . The impeachment power gives Congress authority to root out corruption and abuse of power in the other two branches. 21 Footnote U.S. Const. art. I, § 2, cl. 5 ; id. art. I, § 3, cl. 6 . For a more detailed discussion of the separation of powers and checks and balances, see Intro.7.2 Separation of Powers Under the Constitution and Intro.7.1 Overview of Basic Principles Underlying the Constitution .

  •   Jump to essay-1 The Federalist No. 47 (James Madison) .
  •   Jump to essay-2 The Constitution of Virginia of 1776 provided: The legislative, executive, and judiciary department shall be separate and distinct, so that neither exercise the powers properly belonging to the other; nor shall any person exercise the powers of more than one of them, at the same time[.] The Constitution of Virginia of 1776 , reprinted in 10 Sources and Documents of United States Constitutions 52 (William F. Swindler ed., 1979) . See also 5 id. at 96 . Similarly, the Massachusetts Constitution of 1780 provided: In the government of this commonwealth, the legislative department shall never exercise the executive and judicial powers, or either of them; the executive shall never exercise the legislative and judicial powers, or either of them; the judicial shall never exercise the legislative and executive powers, or either of them; to the end it may be a government of laws and not of men.
  •   Jump to essay-3 The Federalist No. 51 (James Madison) ( In republican government the legislative authority, necessarily, predominates. ). See also id. No. 48 . This theme continues to influence the Court’s evaluation of congressional initiatives. See, e.g., Metro. Wash. Airports Auth. v. Citizens for the Abatement of Aircraft Noise , 501 U.S. 252, 273–74, 277 (1991) . But compare id. at 286 n.3 (White, J., dissenting).
  •   Jump to essay-4 The intellectual history of the Confederation period and the Constitutional Convention is detailed in Gordon S. Wood , The Creation of the American Republic, 1776–1787 (1969) .
  •   Jump to essay-5 See, e.g. , M.J.C. Vile , Constitutionalism and the Separation of Powers (1967) .
  •   Jump to essay-6 The Federalist No. 47 (James Madison) .
  •   Jump to essay-7 U.S. Const. art. I, § 7 .
  •   Jump to essay-8 Id. art. II, § 2, cl. 2 .
  •   Jump to essay-9 See, e.g. , The Federalist No. 47 (James Madison) ( [O]ne of the principal objections inculcated by the more respectable adversaries to the Constitution, is its supposed violation of the political maxim, that the legislative, executive, and judiciary departments ought to be separate and distinct. . . . The several departments of power are distributed and blended in such a manner as at once to destroy all symmetry and beauty of form, and to expose some of the essential parts of the edifice to the danger of being crushed by the disproportionate weight of other parts. ).
  •   Jump to essay-10 Id. Nos. 47–51 (James Madison) .
  •   Jump to essay-11 Id. No. 47 (James Madison) .
  •   Jump to essay-12 Id.
  •   Jump to essay-13 Id. Nos. 47–49 .
  •   Jump to essay-14 Id. No. 51 .
  •   Jump to essay-15 Id.
  •   Jump to essay-16 U.S. Const. art. I, § 1 .
  •   Jump to essay-17 Id. art. I, § 7 .
  •   Jump to essay-18 Id. art. II, § 2, cl. 2 .
  •   Jump to essay-19 Id. art. III, § 1 .
  •   Jump to essay-20 Id. ; Marbury v. Madison , 5 U.S. (1 Cranch.) 137 (1803) .
  •   Jump to essay-21 U.S. Const. art. I, § 2, cl. 5 ; id. art. I, § 3, cl. 6 . For a more detailed discussion of the separation of powers and checks and balances, see Intro.7.2 Separation of Powers Under the Constitution and Intro.7.1 Overview of Basic Principles Underlying the Constitution .
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This Clarence Thomas Dissent Reveals His Favorite Tactic for Constitutional Mayhem

This is part of  Opinionpalooza , Slate’s coverage of the major decisions from the Supreme Court this June. Alongside  Amicus , we kicked things off this year by explaining  How Originalism Ate the Law . The best way to support our work is by joining  Slate Plus . (If you are already a member, consider a  donation  or  merch !)

Justice Clarence Thomas is a master at the art of bogus history—rewriting the past to give the Constitution a new, dubious meaning that happens to align with the Republican Party platform. Even by his own lofty standards, the justice outdid himself in Moore v. U.S. , last week’s major tax case. Thomas’ dissent is a masterwork of partisan historical revisionism, manipulating reality so seamlessly that an unsuspecting reader might actually think he is telling the truth. He isn’t, not even close: Thomas’ goal in Moore is to eviscerate the 16 th Amendment, which legalized the federal income tax in 1913. And, as is so often the case, the justice marshals his argument by diminishing a progressive constitutional amendment as some illegitimate affront to the Framers’ original, divinely inspired design. At this point, it is unclear whether Thomas even acknowledges the full validity of the amendments that made this nation more equal and egalitarian. He is, at a minimum, committed to reading many hard-fought post–Civil War constitutional reforms out of the law altogether.

Conservative attorneys manufactured Moore as a preemptive challenge to a potential future “wealth tax” on affluent Americans’ net assets, including personal property. They seized upon an obscure 2017 provision of the Trump-era tax cuts that taxed shareholders of U.S.–owned corporations located overseas by collecting money on undistributed income. These lawyers argued that the tax was unconstitutional under the 16 th Amendment, which allows Congress “to lay and collect taxes on incomes, from whatever source derived.” The word income , they argued, has a “realization requirement”—meaning that the money must reach a taxpayer’s pockets before the government takes a cut of it. This theory would forestall a wealth tax, since Elon Musk, for instance, hasn’t yet made money on the tens of billions of dollars in Tesla stock he owns.

The Supreme Court wound up ducking the “realization” issue altogether, holding simply that a company’s undistributed income can be attributed to its shareholders. Thomas wrote an angry dissent chastising the majority for “ignoring” the larger question. He embarked upon a journey through a version of history that had not, in fact, occurred, to shrink the 16 th Amendment down to a “narrow meaning” that only “slightly altered” the original Constitution. In the process, he elevated a muddy accommodation for slavery over a signal triumph of the Progressive Era. That’s business as usual for our amateur historian in chief.

Thomas’ sleight of hand revolves around the direct tax clause of the original Constitution. This provision was part and parcel of the three-fifths compromise, which counted enslaved people as three-fifths of a person for purposes of representation and certain taxes. There was, at the time, a common form of taxation that imposed a “head tax” on each individual taxpayer. Delegates to the Constitutional Convention called this a “direct tax.” In exchange for counting slaves as three-fifths of a person with regard to representation—boosting its share of seats in Congress—the South agreed to count slaves as three-fifths of a person with regard to any future “direct tax.” The slave states demanded and received another safeguard: Any direct tax had to be “apportioned” among the states according to their population (with each slave counting as three-fifths of a person). This system would impose wildly disparate tax burdens on Americans and has always been seen as basically impossible.

Thus, as professor Bruce Ackerman has definitively shown , the direct tax emerged as a sordid trade-off with the slave states, giving “a fig-leaf for antislavery Northerners opposed to the explicit grant of extra representation for Southern slaves.” Yes, the South got extra representation because of its slaves, but it also had to pay more taxes—except that the delegates all knew that new direct taxes were highly unlikely, in part because of how this compromise was structured. In fact, they weren’t even sure what a direct tax might look like , beyond the head tax imposed on individuals. Famously, by James Madison’s account, when one delegate asked the convention “what was the precise meaning of direct taxation,” nobody answered . In 1796 the Supreme Court clarified that a head tax was “direct,” as would be an express tax on land. But nothing else qualified.

Pause here and turn to Thomas’ account, which elides almost all the above. According to the justice, the direct tax clause was part of a “delicate” constitutional balance carefully hammered out at the Constitutional Convention to protect states from an overbearing federal government. Dismissing the clause’s roots in slavery, Thomas claimed that it embodied “federalism principles” designed to give “state governments a fiscal safe haven against expanding federal authority.” The limitation, by his telling, was meant to temper “the destructive force of the federal taxing power,” preventing “unjust taxes” that intrude on state sovereignty. He totally whitewashes the real basis of the clause—a fierce dispute between North and South over the Constitution’s accommodations for slavery.

Somehow, it gets even worse. Turning back to actual history, the Supreme Court understood the direct tax clause in its accurate historical context until 1895, when it abruptly struck down the federal income tax in a notorious case called Pollock . As professors Joseph Fishkin and William Forbath illustrate in their book The Anti-Oligarchy Constitution , the court of this period was dead set upon enshrining the legal supremacy of wealthy individuals and corporations. To that end, it redefined the phrase direct tax to encompass income for the first time. And because it was functionally impossible to apportion a tax among the states, the decision essentially outlawed any federal income tax.

There was not much law in Pollock : Rather, the five justices in the majority based their decision on overt hostility toward a fairer tax system. Justice Stephen Field wrote that the income tax constituted “class legislation” that discriminated against rich people, indistinguishable from a special tax on Protestants or Jews. Field framed the tax as a violation of the equality principles enshrined in the post–Civil War amendments. This claim was especially perverse because, as Justice John Marshall Harlan pointed out in dissent, the direct tax clause was rooted in slavery, and the postwar amendments were designed to rid the Constitution of the institution’s stain.

Predictably, Thomas embraces Pollock as the correct reading of the original Constitution. But Americans of the era disagreed. Progressive reformers mobilized to ratify the 16 th Amendment, one of their most enduring victories, in 1913. The amendment marked a “ massive political repudiation ” of the court’s oligarchical constitutionalism, overruling Pollock and handing Congress the sweeping power to tax income “from whatever source derived.” To Thomas, however, the 16 th Amendment was barely a footnote, a “narrow” change that “left everything else in place, including the federalism principles bound up” in the direct tax clause. (These are “principles” that Thomas just made up.) In Thomas’ account, this groundswell of nationwide support for the income tax—culminating in a grueling and successful crusade to amend the Constitution—was a mere technical tweak with extremely limited effect.

Which leads to the justice’s final, most antidemocratic attempted move in his Moore dissent: transforming the 16 th Amendment from a populist expansion of Congress’ taxing power into a novel restriction on that power. Recall that the amendment allows taxation of income, “from whatever source derived.” There is a wealth of evidence that lawmakers included this phrase to ensure that courts would not artificially narrow the definition of income —a word that was, at the time , widely understood in broad terms , encompassing both realized and unrealized gains . Yet Thomas spurned the historical record in favor of some characteristic sophistry: The word derived , he wrote (without any evidence or support), is a “near-synonym” for realized . It therefore “points to the concept of realization” as an extratextual limitation on Congress’ taxing power.

Responding to Thomas’ opinion, the legal historian Fishkin derided this word game as “an absolute classic of the genre” in which Thomas excels: “to read language that is quite obviously on its face intended to be as broad as possible as instead narrowing language.” The purpose of that phrase, he told me, “was not the word derived . It was the word whatever . It meant—because this was a point of contention at the time—that even income from land could be taxed. It didn’t matter what source the income was derived from. That’s the straightforward and obvious meaning.” Fishkin added, “The word derived happens to be the one he’s playing games with, but really, the text doesn’t matter here. There’s always a word somewhere you can use. The point is that he wants to put in a realization requirement.” And Thomas, ostensibly a committed textualist and originalist, brazenly manipulated both text and history to do it.

There is a profound irony here. The Supreme Court’s 1895 decision in Pollock was obviously wrong , invalidating more than three decades of the income tax. The American people ratified the 16 th Amendment to overrule Pollock . Yet the court initially refused to accept the amendment: It defied the will of the people in 1920’s Eisner v. Macomber , elevating Pollock ’s repudiating interpretation of the vestigial direct tax clause over the 16 th Amendment to limit income taxes once again. Macomber was a hallmark of the court’s Lochner era , when it regularly rewrote the Constitution to favor moneyed interests. It abandoned that approach several years into the New Deal, in the face of President Franklin Delano Roosevelt’s court-packing threat. With Thomas’ Moore dissent, history is repeating itself. The justice wants to turbocharge the direct tax clause (like the Supreme Court did in 1895) and mutilate the 16 th Amendment (like the Supreme Court did in 1920) to reduce the tax burdens on the ultrawealthy. Why? Legal realists can debate the impact of his billionaire friends on Thomas’ jurisprudence.

But there’s another, more explicit bias at work: He simply does not grant constitutional amendments the same respect that he gives to the original Constitution. His jurisprudence is inspired by “natural law,” a theory that interprets the Constitution as, essentially, a divine revelation to the founders that codifies rights bestowed by a higher authority . Under this view, the product of the Constitutional Convention was nearly perfect, minus its accommodation for slavery—yet, as his Moore dissent illustrates, the justice is willing to downplay or write off this glaring defect when necessary.

Thomas will embrace the 14 th Amendment’s equal protection clause to outlaw affirmative action , but he otherwise gives remarkably short shrift to the Reconstruction amendments. These amendments fundamentally altered the balance of power between states and the federal government, giving Congress vastly more authority to enforce a panoply of civil rights. But Thomas routinely interprets them as marginalia at best— shooting down , for instance, Congress’ prerogative to stamp out race discrimination in voting. In these opinions, the justice insists on enforcing aspects of the original Constitution that, he claims, allow states to suppress civil rights and civil liberties without federal interference. The Reconstruction amendments, in his preferred narrative, fall away as an irrelevant relic rather than the radical transformation of the Constitution that they were meant to be.

In Moore , the 16 th Amendment gets the Thomas treatment. His (misleading) account of the amendment’s enactment largely erases the progressive reformers who pushed it over the finish line—as if, to his mind, they have no legitimate role to play in the story of our founding charter. They are written off as interlopers who foolishly tinkered with our God-given Constitution, inserting errors that must be corrected by black-robed rulers who just know better. It’s a frighteningly arrogant approach to judging, one that effectively closes off amendments as a way to fix the court’s mistakes. The Constitution begins with the declaration “We the People” and invites future generations to help build a “more perfect union.” But to Thomas, the wealthy white men who wrote those words got almost everything right the first time, and the people must never be trusted to build upon their flawed work.

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COMMENTS

  1. What Are Footnotes?

    Published on March 28, 2022 by Jack Caulfield . Revised on June 7, 2022. Footnotes are notes placed at the bottom of the page in a piece of academic writing and indicated in the text with superscript numbers (or sometimes letters or other symbols). You can insert footnotes automatically in Word or Google Docs.

  2. Using Footnotes: The Dos And Don'ts

    How to use footnotes correctly. Write your footnotes last - A footnote is commonly, but not always, a shortened version of a citation contained in your bibliography. Whatever content you choose to include, it's usually best to leave your footnotes until the essay is finished and your bibliography is complete. Place a short reminder in the ...

  3. How to Use Footnotes and Endnotes

    To insert a footnote or endnote in a Microsoft Word document, you need to: Go to References > Footnotes on the main ribbon. Select either Insert Footnote or Insert Endnote as required. Type your note in the newly created footnote/endnote. Footnote tools in MS Word. You can also customize the style of footnotes and endnotes by clicking on the ...

  4. What Are Footnotes and How Do You Use Them?

    Learn what footnotes are, how they differ from endnotes, and how to cite sources with them. Find out the rules for using footnotes in MLA, APA, and CMS style guides.

  5. APA Footnotes

    APA footnotes use superscript numbers and should appear in numerical order. You can place footnotes at the bottom of the relevant pages, or on a separate footnotes page at the end: For footnotes at the bottom of the page, you can use your word processor to automatically insert footnotes.; For footnotes at the end of the text in APA, place them on a separate page entitled "Footnotes," after ...

  6. MLA Footnotes & Endnotes

    Providing additional examples that don't fit into the main text. Footnotes appear at the bottom of the relevant page, while endnotes appear at the end of the paper, just before the Works Cited list. MLA allows the use of either type, but stick to one or the other. Any sources you cite in your footnotes or endnotes must also be included in ...

  7. MLA Endnotes and Footnotes

    MLA (Modern Language Association) style is most commonly used to write papers and cite sources within the liberal arts and humanities. This resource, updated to reflect the MLA Handbook (9th ed.), offers examples for the general format of MLA research papers, in-text citations, endnotes/footnotes, and the Works Cited page.

  8. What Are Footnotes and How to Use Them

    Footnotes usually appear at the bottom of the page. Each footnote is preceded by a number that also appears as a superscript after the corresponding material on that page. Chicago style allows you to use symbols, such as the asterisk or the dagger, instead of numbers if you only have a few footnotes. 3. If you're following APA style or MLA ...

  9. How To Do & Write Footnotes: What To Put In Them

    Create the corresponding footnote at the bottom of the page. The footnote itself begins with the same superscript number, followed by the content of the note. Ensure it's clearly separated from the main text, typically by a horizontal line across the column. Format the footnote content according to the guidelines of the citation style you are ...

  10. How do you put footnotes in an essay?

    Mastering Footnote Placement in Essays • Footnote Pro Tips • Learn how to seamlessly insert footnotes into your essays with this step-by-step guide. Follow t...

  11. Footnotes in a Paper: How to Use Them Effectively in Your Writing

    Footnotes are a useful tool in academic writing that allows for the inclusion of additional information or comments in a document or text. Typically denoted by a small number or symbol in the main text, footnotes in a paper appear at the bottom of the page and can serve a variety of purposes. For example, footnotes can be used to clarify a ...

  12. How to Write Footnotes in MLA and APA

    How to Write a Footnote Citation in MLA. Place footnotes at the bottom of the page in their own special section. Follow the same numerical order on the page. Firstly, start each note with the superscript number that corresponds with the in-text citation. Then, remember that bibliographical notes provide citations similar to the works cited and ...

  13. Footnotes and Endnotes

    Footnotes appear on the bottom of the page that contains the sentence to which it refers. Endnotes are listed at the end of the paper on separate pages. On the top of the first page, the title "Notes" is centered one inch from the top of the page. Endnote pages are placed before the bibliography. Many professors prefer footnotes to endnotes.

  14. Footnotes or Endnotes?

    Things to keep in mind when considering using either endnotes or footnotes in your research paper:. 1. Footnotes are numbered consecutively throughout a research paper, except for those notes accompanying special material (e.g., figures, tables, charts, etc.). Numbering of footnotes are "superscript"--Arabic numbers typed slightly above the line of text.

  15. What are Footnotes and How to Use Them for Research?

    Navigate to the "References" tab and click on the "Insert Footnote" button. A small superscript number (typically "1") will appear where you positioned the cursor, and a corresponding footnote area will appear at the bottom of the page. Enter your footnote content in this designated area. To insert additional footnotes, repeat the ...

  16. How to Use Footnotes and Endnotes in Essays

    To insert a footnote or endnote in a Microsoft Word document, you need to: Go to References > Footnotes on the main ribbon. Select either Insert Footnote or Insert Endnote as required. Type your note in the newly created footnote/endnote. Footnote tools in MS Word. You can also customise the style of footnotes and endnotes by clicking on the ...

  17. Footnotes

    Footnotes are short numbered notes that are placed at the bottom of the page in an essay or article. They are used for a variety of reasons including, citing materials, providing notes on a source or topic, and to acknowledge copyright status.

  18. Footnotes : Punctuating Essays and Letters

    Footnotes. A footnote is a piece of text which, for some reason, cannot be accommodated within the main body of the document and which is therefore placed elsewhere. It is usual, and preferable, to place footnotes at the bottom of the page on which they are referred to, but this usually requires a great deal of fiddling about, unless you are lucky enough to have a word processor which arranges ...

  19. Footnotes, endnotes, and citations

    Long-term research essays and theses. If you are doing a long-term research project, you should use the full and proper citation, either in a footnote, an endnote or in the text. Again, once you have given the citation in full, you may use the appropriate short citation. Very often, instructors will give formatting advice for long-term research ...

  20. Citing a Chapter or Essay in a Book

    Footnote/Endnote. Author First M. Last Name, "Chapter or Essay Title," in Book Title, ed. First M. Last Name (Place of Publication: Publisher, date), page cited. Short version: Author Last Name, "Chapter or Essay Title (shortened if necessary)," page cited. Bibliography.

  21. What Are Endnotes?

    Endnotes are notes that appear at the end of your text in a piece of academic writing. They're indicated in the text with numbers (or occasionally other symbols). Endnotes are used: For citations in certain styles. To add extra information that doesn't fit smoothly into the main text.

  22. Separation of Powers and Checks and Balances

    Footnotes Jump to essay-1 The Federalist No. 47 (James Madison). Jump to essay-2 The Constitution of Virginia of 1776 provided: The legislative, executive, and judiciary department shall be separate and distinct, so that neither exercise the powers properly belonging to the other; nor shall any person exercise the powers of more than one of them, at the same time[.]

  23. This Clarence Thomas Dissent Reveals His Favorite Tactic for

    To Thomas, however, the 16 th Amendment was barely a footnote, a "narrow" change that "left everything else in place, including the federalism principles bound up" in the direct tax clause ...