If you've spent any time with The Bluebook: A Uniform System of Citation, you know Rule 8 (restated as B8 in the Bluepages for practitioner documents): capitalize the first and last word of a title, capitalize all major words, and lowercase articles, conjunctions, and prepositions of four letters or fewer unless they open the title, close it, or follow a colon. It's a clean rule, and it's easy to apply once you've internalized the four-letter cutoff.
The trouble starts when writers apply that same rule to case names. United States v. Nixon is not a title. It's a case name, and case names live under an entirely different rule — Rule 10 (B10 in the Bluepages) — which has nothing to do with major words, minor words, or letter counts.
What Rule 8 actually covers
Rule 8's title-case rule applies to:
- Article titles (law review pieces, journal articles)
- Book titles
- Headings within a document
It does not apply to case names, statutory titles, or the names of courts and parties in a citation. Those live under separate rules with their own logic.
The case-name rule: Bluebook Rule 10
Case names follow ordinary sentence-style capitalization for the party names themselves — not title case. There's no "major word" test to run. You capitalize proper nouns the way you'd capitalize them anywhere else, and the two parties are joined by a lowercase, abbreviated v.
| Correct | Common mistake |
|---|---|
| United States v. Nixon | United States V. Nixon |
| Brown v. Board of Education | Brown Vs. Board of Education |
| Marbury v. Madison | Marbury Versus Madison |
| Roe v. Wade | Roe V Wade (missing period) |
Three things to internalize:
- "v." is always lowercase — never capitalized, regardless of where it falls in a sentence or heading.
- "v." is always abbreviated with a period — never spelled out as "versus," never written as "vs." or "Vs."
- No major/minor word logic applies — you're not deciding whether "of," "the," or "board" should be capitalized based on length. Party names get ordinary proper-noun capitalization, full stop.
Why the confusion happens
It's an easy mistake to make, for a specific reason: Bluebook citations mix multiple typeface and capitalization systems in the same document, sometimes in the same sentence. An article title in a footnote is italicized and title-cased under Rule 8. Two lines later, a case name in the same footnote is in ordinary roman type and capitalized under Rule 10. If you're skimming rules rather than reading them rule-by-rule, it's natural to assume one capitalization system governs the whole citation. It doesn't.
The visual cue that should stop you: if you're capitalizing something that includes a "v." separating two parties, you're in Rule 10 territory, not Rule 8. If you're capitalizing the title of a piece of writing — an article, a book, a chapter — you're in Rule 8 territory, and that's where our Bluebook title case rules and converter apply.
Other Rule 8 exceptions worth knowing
Case names are the biggest and most common exception, but they're not the only place Rule 8 doesn't reach:
- Statutory and regulatory titles — Rules 12 and 14 cover acts, codes, and administrative materials with their own conventions.
- Court names — "Court" is capitalized under B8 specifically when referring to the court a document is filed in, independent of the general title-case rule.
- Party designations in captions — court-filing captions follow local court rules, which Bluebook explicitly defers to (see BT.2.2) rather than imposing Rule 8.
Italics: the other detail people miss
Article titles and book titles under Rule 8 are conventionally set in italics in a citation. Case names under Rule 10 are typically set in ordinary roman type in the main text of scholarly writing (with italics reserved for the short-form citation and certain procedural phrases like ex rel.). If you're pasting a title-cased result into a citation, remember that the capitalization tool only handles the letters — you still need to apply the correct typeface convention for whichever rule you're working under.
A quick worked example
Suppose you're writing a law review footnote that cites both an article and references a case within the same sentence:
Jane R. Doe, The Rule Against Perpetuities in Modern Trust Law, 45 Harv. L. Rev. 112 (2026) (discussing Perpetuity Trust Co. v. Smith).
Notice the article title is italicized and title-cased under Rule 8 ("The Rule Against Perpetuities in Modern Trust Law" — note "Against" stays capitalized because it's a five-letter preposition, while a word like "of" would drop to lowercase mid-title). The case name, by contrast, is capitalized under Rule 10 using ordinary proper-noun rules, with the lowercase "v." joining the two parties.
Try it yourself
Our Bluebook title case converter applies Rule 8 correctly to article and book titles — paste a title, not a case name, and you'll get properly capitalized output with the four-letter preposition cutoff applied automatically. For case names, the rule is simpler than it looks once you know it's a different rule entirely: capitalize the proper nouns, lowercase and abbreviate "v.," and skip the major/minor word analysis altogether.
Sources
This article summarizes public guidance from The Bluebook: A Uniform System of Citation, 21st edition.
- The Bluebook — official reference, Harvard Law Review Association
- Cornell Legal Information Institute — Introduction to Basic Legal Citation — freely accessible companion reference