Therefore, the most common format for a Supra short form citation consists of the author's last name followed " supra," offset by a comma. "Supra" citations are most commonly used for secondary authority, such as books and periodicals. NOTE: This is also true for materials such as restatements, legislative documents (other than hearings), and model codes which typically have similar citation formats. Rule 4.2 contains a complete, detailed list of which materials may and may not be cited to using "Supra." Note, however, that in general most forms of primary legal authority (cases, statutes, etc.) should not be referred to using "Supra." "Supra" may be used to refer to certain types of previously cited materials as well as internal cross-references.
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