A citational signal used in legal writing to direct the reader to material appearing later in the same document or text.
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6
Political Contribution Inquiry
A law firm partner prepares a memo analyzing whether contributions to judicial candidates could affect eligibility for government contracts. The partner notes the relevant ethics analysis infra and applies the rule to facts involving Inertia Dynamics seeking municipal bond work after making donations.
Negligence Standard Applied
Israel Irving sues a contractor after a scaffold collapse. Counsel's brief sets out the duty of care and states that the unreasonable risk analysis appears infra, applying the standard to the contractor's failure to secure the equipment properly.
Indigo Textiles holds a junior mortgage on an office building. Its counsel files a brief explaining rent allocation rules and directs the reader to the priority analysis infra, applying the rule to rents collected before a senior receiver takes over.
Contributory Negligence Defense
Ivy Ibarra is injured in a car accident and sues the other driver. Defense counsel's memorandum outlines the plaintiff's duty of self-protection and places the cooperating cause discussion infra, applying the standard to her failure to brake in time.
Rent Retention Rights
Ironclad Industries, as junior mortgagee, obtains a receiver who collects net rents. Counsel's motion cites the retention rule and states the senior mortgagee priority analysis appears infra, applying the rule to the $50,000 collected before the senior receiver is appointed.
Landmark Regulation Challenge
Penn Central challenges the city's landmarks law restricting air rights development. Counsel's brief explains the takings analysis and places the comparison to prior air rights cases infra, applying the rule to the denial of the proposed tower above Grand Central.
Penn Central Transportation Co. et al. v. New York City438 U.S. 104, 98 S.Ct. 2646, 57 L.Ed.2d 631 (1978)
In 1965 New York City enacted the Landmarks Preservation Law, which created an eleven-member Landmarks Preservation Commission and authorized it to designate buildings at least thirty years old that possess special historical or aesthetic interest.
The law required owners of designated landmarks to obtain Commission approval before altering exterior architectural features and imposed an affirmative duty to keep those features in good repair. In August 1967 the Commission designated Grand Central Terminal a landmark and the city tax block it occupies a landmark site; the Board of Estimate confirmed the designation the following month.
Penn Central Transportation Co. and its affiliates owned the Terminal, an eight-story Beaux-Arts structure completed in 1913 that served as the main station for the New York Central and Harlem lines. On January 22, 1968, Penn Central entered a fifty-year renewable lease with UGP Properties, Inc., under which UGP agreed to construct a multistory office building cantilevered above the Terminal and to pay Penn Central at least three million dollars annually after construction.
Penn Central and UGP submitted two plans prepared by architect Marcel Breuer: Breuer I, a fifty-five-story tower resting on the Terminal roof, and Breuer II Revised, a fifty-three-story building that would have removed part of the 42d Street facade. After four days of hearings at which over 80 witnesses testified, the Commission denied this application as to both proposals.
Penn Central filed suit in New York Supreme Court, Trial Term, seeking a declaratory judgment, injunctive relief, and damages for a temporary taking. The trial court granted the injunctive and declaratory relief. The Appellate Division reversed, holding that Penn Central had failed to prove deprivation of all reasonable beneficial use. The New York Court of Appeals affirmed, concluding that the Terminal could still earn a reasonable return and that transferable development rights provided significant compensation. The Supreme Court noted probable jurisdiction.
When should a writer use infra instead of supra in a legal memorandum?
Infra signals that the cited material appears later in the same document. Supra is used for earlier material. Internal cross-references rely on these signals only in citations, not in the body text.
410 U.S. 113 (1973)
…problem after 1527; and that the preamble to the English legislation of 1803, 43 Geo. 3, c. 58, § 1, referred to in the text, infra , at 136, states that "no adequate means have been hitherto provided for the prevention and punishment of such offenses." : Commonwealth v. Bangs , 9 Mass. 387, 388 (1812);…