By Michael Roy Ortizo

Legal education has long prioritized the formalities of citation techniques, such as those found in the Bluebook. Students often find themselves learning an entirely new citation style upon entering law school, even after mastering other writing forms like the Chicago Manual of Style during their undergraduate studies.[1] However, rapid advancements in AI present an opportunity for a shift within the legal landscape that places greater emphasis on the substance of legal writing as opposed to the form of legal citations.

Student-run law journals underscore the importance of providing accurate legal citations, with many law schools administering Bluebook exams as part of the application process. In 2012, Staci Zaretsky reported on a University of Richmond School of Law student who launched a guerilla campaign against the school’s Bluebook exam, arguing that the 40-hour exam was excessive and unnecessary compared to the four-hour standard final exams.[2] This incident sparked controversy and divided opinions among law students regarding the necessity and value of the Bluebook exam.[3]

Traditionally, law students have dedicated significant time and effort to mastering Bluebooking citation forms for legal publications. Rothman, however, contends that perfect Bluebooking is often less critical in legal practice than in law school.[4] The introduction of AI in legal spaces offers a chance for a paradigm shift, enabling scholars to concentrate on the substantive content of legal writing.

While AI models like ChatGPT have been met with skepticism in the legal community due to concerns about trust, security, and cost, recent advancements demonstrate improvements in accuracy.[5] For instance, GPT-4, ChatGPT’s newest AI model, recently passed a simulated bar exam, scoring in the top 10 percentile of test-takers—a significant leap from the previous model, GPT-3.5, which scored in the bottom 10 percentile.[6]

Capitalizing on these advancements, numerous organizations have developed AI-powered tools for various industries.[7] Legal Ease, for example, offers an AI-tool that assists law students, lawyers, and other legal professionals with Bluebook citations, claiming to generate 100% accurate citations in seconds.[8]

AI holds the potential to reshape the future of legal education, driving a much-needed shift towards substantive content. Although proper Bluebooking may not always be as important in legal practice as it is in law school, AI can alleviate the pressure on students and legal professionals to perfect their citation skills. The potential disruption of the formalisms associated with Bluebooking opens up a wealth of opportunities for legal scholars to allocate more resources to increasing their contributions to legal academia, ultimately enhancing the quality and impact of legal scholarship.

[1] Jordan Rothman, Perfect Bluebooking Is Less Important in Legal Practice Than in Law School, Above the Law (Jan. 19, 2022),

[2] Staci Zaretsky, Law Student Revolts Against Law Review’s Bluebook Exam, Above the Law (Mar. 22, 2012),

[3] Id.

[4] Rothman, supra note 1.

[5] Thomas Bacas, ANALYSIS: Will ChatGPT Bring AI to Law Firms? Not Anytime Soon, Bloomberg L. (Dec. 28, 2022),

[6] Kyle Wiggers, OpenAI Releases GPT-4, a Multimodal AI That It Claims Is State-of-the-Art, TechCrunch (Mar. 14, 2023),

[7] Sunny Betz, The 15 Best AI Tools to Know, BuiltIn (June 9, 2022),

[8] LegalEase Citations, About LegalEase, (last visited Apr. 11, 2023).