For those of us bedeviled by the Bluebook’s complicated, seemingly arbitrary citation rules, it is interesting to note that The Yale Law Journal disputes Harvard Law Review’s claim of responsibility for it. According to the New York Times, two librarians at Yale Law School, Fred R. Shapiro and Julie Graves Krishnawami, “have done impressive archival research and make a persuasive case that their own institution is the guilty party.” Their research disclosed that “the idea of a uniform citation manual came from Yale, and a lot of the specifics of the early rules came from Yale.”

A dispute arose in 1973 over which institution was entitled to the increasingly substantial revenues earned from purchases of the Bluebook required of new law students across the United States. The Fourth Edition, published in 1934, listed the Yale, Columbia, and University of Pennsylvania law reviews, as well as Harvard, as owners of the copyright. Over the years, Harvard took the lead in editorial decisions, production, and distribution of the Bluebook, and retained all the sales revenues until challenged by Yale. Since around 1976, the income has been divided among the four schools, although Harvard keeps the largest share. The Yale librarians acknowledge that “[s]ome readers may question whether originating the hyper-complicated Bluebook should be a source of pride for Yale. . . Our response is that, although the Bluebook version that subsequently developed under the leadership of Harvard Law Review currently consists of 582 fairly large pages, the two earliest Yale precursors of the Bluebook were, respectively, one page and fifteen pages long. . . And these were very small pages.”