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Citing textual evidence is critical to academic writing, professional communications, and even everyday discussions where arguments need to be supported by facts. Your ability to reference specific parts of a text improves credibility and strengthens your arguments, allowing you to present a well-rounded and persuasive case. For this reason, we wanted to give you a quick overview of how to cite evidence effectively, using one method in particular – the RACE strategy .

Introduction to Citing Text Evidence

The core reason for citing evidence is to lend credibility to an argument , showing the audience that the points being made are not just based on personal opinion but are backed by solid references. This practice is foundational in academic settings. There, the questions that students need to respond to are often constructed in a way that requires citing of evidence to support their answers. However, how can we make this process more quick and effectice? The answer lies in the RACE strategy, which is a special framework called to streamlines the process of citing textual evidence.

What is the RACE Strategy?

The RACE strategy stands for Restate, Answer, Cite evidence, and Explain. It is a methodical approach designed to help individuals construct well-structured answers that include textual proof. Let’s break down this method a little bit so you have some kind of impression on what we are going to talk about further.

• Restating the question or prompt in the introduction of the answer helps the writer to set the stage for a clear response.
• The direct answer, taht follows afterwards, presents the key point or thesis of the question.
• After we’e given an answer, we can move on to citing evidence, where we will integrate specific examples from the text to support the answer.
• Finally, we can move on to explaining our evidence. Here, it’s important to elaborating on how the cited examples support the argument we made.

This structured approach not only helps in organizing thoughts but also makes sure that the necessary components of a well-supported argument are present. Just like how to cite the constitution you have to be precise and factual. Let’s explore each step with actual examples to better illustrate how this strategy can help you with the process of citing textual evidence.

Restating basically means paraphrasing the original question or statement within your answer. This step demonstrates your understanding of the question and sets the stage for your response.

By answering directly, you respond to the question and therefore briefly present your main argument or thesis. You should stay clear and concise here, providing a straightforward statement of your position or understanding.

Cite Evidence

Citing evidence is where you integrate specific examples from the text to support your answer. This involves quoting or paraphrasing passages and pointing out where in the text your evidence can be found. Don’t forget to use quotation marks appropriately for direct quotes and to provide context for your citations or let a legal citation machine handle it.

For instance, to support the theme of racial injustice, you might cite evidence by saying,

When explaining, you elaborat on how your cited evidence supports your answer. This step connects your evidence back to your main argument, demonstrating a deeper understanding of the text.

After citing evidence, an explanation could be structured the following way,

To put it all together, here’s how an integrated response using the RACE strategy might look:

Response : ⬇

“The novel ‘To Kill a Mockingbird’ primarily explores themes such as racial injustice and the loss of innocence. One of the central themes is racial injustice, which is depicted through the trial of Tom Robinson and its impact on the town of Maycomb. Harper Lee illustrates this theme through the character of Atticus Finch, who states, ‘In our courts, when it’s a white man’s word against a black man’s, the white man always wins.’ (Lee, 1960, p. 295). This quote highlights the deeply ingrained racial biases within the judicial system of Maycomb, underscoring the novel’s critique of racial injustice and its effects on individuals and society as a whole.”

By following the RACE strategy and using actual examples, you can effectively structure clear and relevant responses that add depth to your argumentation. This method not only help in organizing thoughts but also in demonstrating a deep understanding of the text and its main topics.

However, there are a few nuances that you have to be aware of. The first one is the use of quotation marks. Don’t forget them when referencing direct quotes from a text, as they indicate that you took those words verbatim. Furthermore, you have to understand and use citation styles relevant to the discipline or context you write on. This will help you appropriately format your references and avoid unintentional plagiarizing. A quick tip: sentence starters and tags for dialogue can also help with introduction of quoted or paraphrased evidence effectively, as they let the reader or listener easily follow the argument’s progression.

Still not sure? Try our Free Citation Generator

Adapting the race strategy for distance learning.

Even in the case of distance learnign , the RACE strategy remains a valuable tool for teaching students how to cite evidence effectively. Digital resources such as Google Docs often offer collaborative platforms where teachers can share templates, sentence stems, and color-coded examples to guide students through the response building process.

Moreover, interactive activities facilitated through online tools, can further engage students in practicing citing evidence, with digital resources providing immediate feedback and opportunities for revision. This adaptation help develop the skill of citing textual evidence even in a remote learning setting.

It’s hard to argue that citing textual evidence is useful skill that can help you get far in your academic writing as well as in other more professional fields. Following the RACE strategy and using our tips on referencing, you, as students, can create well-structured and compelling responses (which no professor could argue with).

How can I use the RACE strategy to improve my essay writing?

You can use the RACE strategy to structure your paragraphs or entire essays by ensuring that each section includes a restatement of the question (if applicable), a clear answer or thesis statement, cited evidence from your sources, and an explanation of how this evidence supports your argument. This approach can enhance clarity, coherence, and persuasiveness.

What are some tips for effectively citing evidence in my writing?

Some tips for effectively citing evidence are: using direct quotes from the text with proper quotation marks, paraphrasing accurately while maintaining the original meaning, providing specific examples, and ensuring that your citations are relevant and support your argument. Always include page numbers or other locator information if available.

Is the RACE strategy useful for standardized tests or only for classroom assignments?

The RACE strategy is beneficial for a wide range of writing tasks, including standardized tests, classroom assignments, and even professional writing. Its structured approach to constructing responses makes it a valuable tool for any situation requiring evidence-based writing.

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What this handout is about

This handout will provide a broad overview of gathering and using evidence. It will help you decide what counts as evidence, put evidence to work in your writing, and determine whether you have enough evidence. It will also offer links to additional resources.

Introduction

Many papers that you write in college will require you to make an argument ; this means that you must take a position on the subject you are discussing and support that position with evidence. It’s important that you use the right kind of evidence, that you use it effectively, and that you have an appropriate amount of it. If, for example, your philosophy professor didn’t like it that you used a survey of public opinion as your primary evidence in your ethics paper, you need to find out more about what philosophers count as good evidence. If your instructor has told you that you need more analysis, suggested that you’re “just listing” points or giving a “laundry list,” or asked you how certain points are related to your argument, it may mean that you can do more to fully incorporate your evidence into your argument. Comments like “for example?,” “proof?,” “go deeper,” or “expand” in the margins of your graded paper suggest that you may need more evidence. Let’s take a look at each of these issues—understanding what counts as evidence, using evidence in your argument, and deciding whether you need more evidence.

What counts as evidence?

Before you begin gathering information for possible use as evidence in your argument, you need to be sure that you understand the purpose of your assignment. If you are working on a project for a class, look carefully at the assignment prompt. It may give you clues about what sorts of evidence you will need. Does the instructor mention any particular books you should use in writing your paper or the names of any authors who have written about your topic? How long should your paper be (longer works may require more, or more varied, evidence)? What themes or topics come up in the text of the prompt? Our handout on understanding writing assignments can help you interpret your assignment. It’s also a good idea to think over what has been said about the assignment in class and to talk with your instructor if you need clarification or guidance.

What matters to instructors?

Instructors in different academic fields expect different kinds of arguments and evidence—your chemistry paper might include graphs, charts, statistics, and other quantitative data as evidence, whereas your English paper might include passages from a novel, examples of recurring symbols, or discussions of characterization in the novel. Consider what kinds of sources and evidence you have seen in course readings and lectures. You may wish to see whether the Writing Center has a handout regarding the specific academic field you’re working in—for example, literature , sociology , or history .

What are primary and secondary sources?

A note on terminology: many researchers distinguish between primary and secondary sources of evidence (in this case, “primary” means “first” or “original,” not “most important”). Primary sources include original documents, photographs, interviews, and so forth. Secondary sources present information that has already been processed or interpreted by someone else. For example, if you are writing a paper about the movie “The Matrix,” the movie itself, an interview with the director, and production photos could serve as primary sources of evidence. A movie review from a magazine or a collection of essays about the film would be secondary sources. Depending on the context, the same item could be either a primary or a secondary source: if I am writing about people’s relationships with animals, a collection of stories about animals might be a secondary source; if I am writing about how editors gather diverse stories into collections, the same book might now function as a primary source.

Where can I find evidence?

Here are some examples of sources of information and tips about how to use them in gathering evidence. Ask your instructor if you aren’t sure whether a certain source would be appropriate for your paper.

Print and electronic sources

Books, journals, websites, newspapers, magazines, and documentary films are some of the most common sources of evidence for academic writing. Our handout on evaluating print sources will help you choose your print sources wisely, and the library has a tutorial on evaluating both print sources and websites. A librarian can help you find sources that are appropriate for the type of assignment you are completing. Just visit the reference desk at Davis or the Undergraduate Library or chat with a librarian online (the library’s IM screen name is undergradref).

Observation

Sometimes you can directly observe the thing you are interested in, by watching, listening to, touching, tasting, or smelling it. For example, if you were asked to write about Mozart’s music, you could listen to it; if your topic was how businesses attract traffic, you might go and look at window displays at the mall.

An interview is a good way to collect information that you can’t find through any other type of research. An interview can provide an expert’s opinion, biographical or first-hand experiences, and suggestions for further research.

Surveys allow you to find out some of what a group of people thinks about a topic. Designing an effective survey and interpreting the data you get can be challenging, so it’s a good idea to check with your instructor before creating or administering a survey.

Experiments

Experimental data serve as the primary form of scientific evidence. For scientific experiments, you should follow the specific guidelines of the discipline you are studying. For writing in other fields, more informal experiments might be acceptable as evidence. For example, if you want to prove that food choices in a cafeteria are affected by gender norms, you might ask classmates to undermine those norms on purpose and observe how others react. What would happen if a football player were eating dinner with his teammates and he brought a small salad and diet drink to the table, all the while murmuring about his waistline and wondering how many fat grams the salad dressing contained?

Personal experience

Using your own experiences can be a powerful way to appeal to your readers. You should, however, use personal experience only when it is appropriate to your topic, your writing goals, and your audience. Personal experience should not be your only form of evidence in most papers, and some disciplines frown on using personal experience at all. For example, a story about the microscope you received as a Christmas gift when you were nine years old is probably not applicable to your biology lab report.

Using evidence in an argument

Does evidence speak for itself.

Absolutely not. After you introduce evidence into your writing, you must say why and how this evidence supports your argument. In other words, you have to explain the significance of the evidence and its function in your paper. What turns a fact or piece of information into evidence is the connection it has with a larger claim or argument: evidence is always evidence for or against something, and you have to make that link clear.

As writers, we sometimes assume that our readers already know what we are talking about; we may be wary of elaborating too much because we think the point is obvious. But readers can’t read our minds: although they may be familiar with many of the ideas we are discussing, they don’t know what we are trying to do with those ideas unless we indicate it through explanations, organization, transitions, and so forth. Try to spell out the connections that you were making in your mind when you chose your evidence, decided where to place it in your paper, and drew conclusions based on it. Remember, you can always cut prose from your paper later if you decide that you are stating the obvious.

Here are some questions you can ask yourself about a particular bit of evidence:

• OK, I’ve just stated this point, but so what? Why is it interesting? Why should anyone care?
• What does this information imply?
• What are the consequences of thinking this way or looking at a problem this way?
• I’ve just described what something is like or how I see it, but why is it like that?
• I’ve just said that something happens—so how does it happen? How does it come to be the way it is?
• Why is this information important? Why does it matter?
• How is this idea related to my thesis? What connections exist between them? Does it support my thesis? If so, how does it do that?
• Can I give an example to illustrate this point?

Answering these questions may help you explain how your evidence is related to your overall argument.

How can I incorporate evidence into my paper?

There are many ways to present your evidence. Often, your evidence will be included as text in the body of your paper, as a quotation, paraphrase, or summary. Sometimes you might include graphs, charts, or tables; excerpts from an interview; or photographs or illustrations with accompanying captions.

When you quote, you are reproducing another writer’s words exactly as they appear on the page. Here are some tips to help you decide when to use quotations:

• Quote if you can’t say it any better and the author’s words are particularly brilliant, witty, edgy, distinctive, a good illustration of a point you’re making, or otherwise interesting.
• Quote if you are using a particularly authoritative source and you need the author’s expertise to back up your point.
• Quote if you are analyzing diction, tone, or a writer’s use of a specific word or phrase.
• Quote if you are taking a position that relies on the reader’s understanding exactly what another writer says about the topic.

Be sure to introduce each quotation you use, and always cite your sources. See our handout on quotations for more details on when to quote and how to format quotations.

Like all pieces of evidence, a quotation can’t speak for itself. If you end a paragraph with a quotation, that may be a sign that you have neglected to discuss the importance of the quotation in terms of your argument. It’s important to avoid “plop quotations,” that is, quotations that are just dropped into your paper without any introduction, discussion, or follow-up.

Paraphrasing

When you paraphrase, you take a specific section of a text and put it into your own words. Putting it into your own words doesn’t mean just changing or rearranging a few of the author’s words: to paraphrase well and avoid plagiarism, try setting your source aside and restating the sentence or paragraph you have just read, as though you were describing it to another person. Paraphrasing is different than summary because a paraphrase focuses on a particular, fairly short bit of text (like a phrase, sentence, or paragraph). You’ll need to indicate when you are paraphrasing someone else’s text by citing your source correctly, just as you would with a quotation.

When might you want to paraphrase?

• Paraphrase when you want to introduce a writer’s position, but their original words aren’t special enough to quote.
• Paraphrase when you are supporting a particular point and need to draw on a certain place in a text that supports your point—for example, when one paragraph in a source is especially relevant.
• Paraphrase when you want to present a writer’s view on a topic that differs from your position or that of another writer; you can then refute writer’s specific points in your own words after you paraphrase.
• Paraphrase when you want to comment on a particular example that another writer uses.
• Paraphrase when you need to present information that’s unlikely to be questioned.

When you summarize, you are offering an overview of an entire text, or at least a lengthy section of a text. Summary is useful when you are providing background information, grounding your own argument, or mentioning a source as a counter-argument. A summary is less nuanced than paraphrased material. It can be the most effective way to incorporate a large number of sources when you don’t have a lot of space. When you are summarizing someone else’s argument or ideas, be sure this is clear to the reader and cite your source appropriately.

Statistics, data, charts, graphs, photographs, illustrations

Sometimes the best evidence for your argument is a hard fact or visual representation of a fact. This type of evidence can be a solid backbone for your argument, but you still need to create context for your reader and draw the connections you want them to make. Remember that statistics, data, charts, graph, photographs, and illustrations are all open to interpretation. Guide the reader through the interpretation process. Again, always, cite the origin of your evidence if you didn’t produce the material you are using yourself.

Do I need more evidence?

Let’s say that you’ve identified some appropriate sources, found some evidence, explained to the reader how it fits into your overall argument, incorporated it into your draft effectively, and cited your sources. How do you tell whether you’ve got enough evidence and whether it’s working well in the service of a strong argument or analysis? Here are some techniques you can use to review your draft and assess your use of evidence.

Make a reverse outline

A reverse outline is a great technique for helping you see how each paragraph contributes to proving your thesis. When you make a reverse outline, you record the main ideas in each paragraph in a shorter (outline-like) form so that you can see at a glance what is in your paper. The reverse outline is helpful in at least three ways. First, it lets you see where you have dealt with too many topics in one paragraph (in general, you should have one main idea per paragraph). Second, the reverse outline can help you see where you need more evidence to prove your point or more analysis of that evidence. Third, the reverse outline can help you write your topic sentences: once you have decided what you want each paragraph to be about, you can write topic sentences that explain the topics of the paragraphs and state the relationship of each topic to the overall thesis of the paper.

For tips on making a reverse outline, see our handout on organization .

Color code your paper

You will need three highlighters or colored pencils for this exercise. Use one color to highlight general assertions. These will typically be the topic sentences in your paper. Next, use another color to highlight the specific evidence you provide for each assertion (including quotations, paraphrased or summarized material, statistics, examples, and your own ideas). Lastly, use another color to highlight analysis of your evidence. Which assertions are key to your overall argument? Which ones are especially contestable? How much evidence do you have for each assertion? How much analysis? In general, you should have at least as much analysis as you do evidence, or your paper runs the risk of being more summary than argument. The more controversial an assertion is, the more evidence you may need to provide in order to persuade your reader.

Play devil’s advocate, act like a child, or doubt everything

This technique may be easiest to use with a partner. Ask your friend to take on one of the roles above, then read your paper aloud to them. After each section, pause and let your friend interrogate you. If your friend is playing devil’s advocate, they will always take the opposing viewpoint and force you to keep defending yourself. If your friend is acting like a child, they will question every sentence, even seemingly self-explanatory ones. If your friend is a doubter, they won’t believe anything you say. Justifying your position verbally or explaining yourself will force you to strengthen the evidence in your paper. If you already have enough evidence but haven’t connected it clearly enough to your main argument, explaining to your friend how the evidence is relevant or what it proves may help you to do so.

Common questions and additional resources

• I have a general topic in mind; how can I develop it so I’ll know what evidence I need? And how can I get ideas for more evidence? See our handout on brainstorming .
• Who can help me find evidence on my topic? Check out UNC Libraries .
• I’m writing for a specific purpose; how can I tell what kind of evidence my audience wants? See our handouts on audience , writing for specific disciplines , and particular writing assignments .
• How should I read materials to gather evidence? See our handout on reading to write .
• How can I make a good argument? Check out our handouts on argument and thesis statements .
• How do I tell if my paragraphs and my paper are well-organized? Review our handouts on paragraph development , transitions , and reorganizing drafts .
• How do I quote my sources and incorporate those quotes into my text? Our handouts on quotations and avoiding plagiarism offer useful tips.
• How do I cite my evidence? See the UNC Libraries citation tutorial .
• I think that I’m giving evidence, but my instructor says I’m using too much summary. How can I tell? Check out our handout on using summary wisely.
• I want to use personal experience as evidence, but can I say “I”? We have a handout on when to use “I.”

Works consulted

We consulted these works while writing this handout. This is not a comprehensive list of resources on the handout’s topic, and we encourage you to do your own research to find additional publications. Please do not use this list as a model for the format of your own reference list, as it may not match the citation style you are using. For guidance on formatting citations, please see the UNC Libraries citation tutorial . We revise these tips periodically and welcome feedback.

Lunsford, Andrea A., and John J. Ruszkiewicz. 2016. Everything’s an Argument , 7th ed. Boston: Bedford/St Martin’s.

Miller, Richard E., and Kurt Spellmeyer. 2016. The New Humanities Reader , 5th ed. Boston: Cengage.

University of Maryland. 2019. “Research Using Primary Sources.” Research Guides. Last updated October 28, 2019. https://lib.guides.umd.edu/researchusingprimarysources .

You may reproduce it for non-commercial use if you use the entire handout and attribute the source: The Writing Center, University of North Carolina at Chapel Hill

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Using evidence.

Like a lawyer in a jury trial, a writer must convince her audience of the validity of her argument by using evidence effectively. As a writer, you must also use evidence to persuade your readers to accept your claims. But how do you use evidence to your advantage? By leading your reader through your reasoning.

The types of evidence you use change from discipline to discipline--you might use quotations from a poem or a literary critic, for example, in a literature paper; you might use data from an experiment in a lab report.

The process of putting together your argument is called analysis --it interprets evidence in order to support, test, and/or refine a claim . The chief claim in an analytical essay is called the thesis . A thesis provides the controlling idea for a paper and should be original (that is, not completely obvious), assertive, and arguable. A strong thesis also requires solid evidence to support and develop it because without evidence, a claim is merely an unsubstantiated idea or opinion.

This Web page will cover these basic issues (you can click or scroll down to a particular topic):

• Incorporating evidence effectively.
• Integrating quotations smoothly.
• Citing your sources.

Incorporating Evidence Into Your Essay

When should you incorporate evidence.

Once you have formulated your claim, your thesis (see the WTS pamphlet, " How to Write a Thesis Statement ," for ideas and tips), you should use evidence to help strengthen your thesis and any assertion you make that relates to your thesis. Here are some ways to work evidence into your writing:

• Offer evidence that agrees with your stance up to a point, then add to it with ideas of your own.
• Present evidence that contradicts your stance, and then argue against (refute) that evidence and therefore strengthen your position.
• Use sources against each other, as if they were experts on a panel discussing your proposition.
• Use quotations to support your assertion, not merely to state or restate your claim.

Weak and Strong Uses of Evidence

In order to use evidence effectively, you need to integrate it smoothly into your essay by following this pattern:

• State your claim.
• Give your evidence, remembering to relate it to the claim.
• Comment on the evidence to show how it supports the claim.

To see the differences between strong and weak uses of evidence, here are two paragraphs.

Weak use of evidence

Today, we are too self-centered. Most families no longer sit down to eat together, preferring instead to eat on the go while rushing to the next appointment (Gleick 148). Everything is about what we want.

This is a weak example of evidence because the evidence is not related to the claim. What does the claim about self-centeredness have to do with families eating together? The writer doesn't explain the connection.

The same evidence can be used to support the same claim, but only with the addition of a clear connection between claim and evidence, and some analysis of the evidence cited.

Stronger use of evidence

Today, Americans are too self-centered. Even our families don't matter as much anymore as they once did. Other people and activities take precedence. In fact, the evidence shows that most American families no longer eat together, preferring instead to eat on the go while rushing to the next appointment (Gleick 148). Sit-down meals are a time to share and connect with others; however, that connection has become less valued, as families begin to prize individual activities over shared time, promoting self-centeredness over group identity.

This is a far better example, as the evidence is more smoothly integrated into the text, the link between the claim and the evidence is strengthened, and the evidence itself is analyzed to provide support for the claim.

Using Quotations: A Special Type of Evidence

One effective way to support your claim is to use quotations. However, because quotations involve someone else's words, you need to take special care to integrate this kind of evidence into your essay. Here are two examples using quotations, one less effective and one more so.

Ineffective Use of Quotation

Today, we are too self-centered. "We are consumers-on-the-run . . . the very notion of the family meal as a sit-down occasion is vanishing. Adults and children alike eat . . . on the way to their next activity" (Gleick 148). Everything is about what we want.

This example is ineffective because the quotation is not integrated with the writer's ideas. Notice how the writer has dropped the quotation into the paragraph without making any connection between it and the claim. Furthermore, she has not discussed the quotation's significance, which makes it difficult for the reader to see the relationship between the evidence and the writer's point.

A More Effective Use of Quotation

Today, Americans are too self-centered. Even our families don't matter as much any more as they once did. Other people and activities take precedence, as James Gleick says in his book, Faster . "We are consumers-on-the-run . . . the very notion of the family meal as a sit-down occasion is vanishing. Adults and children alike eat . . . on the way to their next activity" (148). Sit-down meals are a time to share and connect with others; however, that connection has become less valued, as families begin to prize individual activities over shared time, promoting self-centeredness over group identity.

The second example is more effective because it follows the guidelines for incorporating evidence into an essay. Notice, too, that it uses a lead-in phrase (". . . as James Gleick says in his book, Faster ") to introduce the direct quotation. This lead-in phrase helps to integrate the quotation with the writer's ideas. Also notice that the writer discusses and comments upon the quotation immediately afterwards, which allows the reader to see the quotation's connection to the writer's point.

REMEMBER: Discussing the significance of your evidence develops and expands your paper!

Citing Your Sources

Evidence appears in essays in the form of quotations and paraphrasing. Both forms of evidence must be cited in your text. Citing evidence means distinguishing other writers' information from your own ideas and giving credit to your sources. There are plenty of general ways to do citations. Note both the lead-in phrases and the punctuation (except the brackets) in the following examples:

Quoting: According to Source X, "[direct quotation]" ([date or page #]).

Paraphrasing: Although Source Z argues that [his/her point in your own words], a better way to view the issue is [your own point] ([citation]).

Summarizing: In her book, Source P's main points are Q, R, and S [citation].

Your job during the course of your essay is to persuade your readers that your claims are feasible and are the most effective way of interpreting the evidence.

Questions to Ask Yourself When Revising Your Paper

• Have I offered my reader evidence to substantiate each assertion I make in my paper?
• Do I thoroughly explain why/how my evidence backs up my ideas?
• Do I avoid generalizing in my paper by specifically explaining how my evidence is representative?
• Do I provide evidence that not only confirms but also qualifies my paper's main claims?
• Do I use evidence to test and evolve my ideas, rather than to just confirm them?
• Do I cite my sources thoroughly and correctly?

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Using Evidence: Analysis

Beyond introducing and integrating your paraphrases and quotations, you also need to analyze the evidence in your paragraphs. Analysis is your opportunity to contextualize and explain the evidence for your reader. Your analysis might tell the reader why the evidence is important, what it means, or how it connects to other ideas in your writing.

Note that analysis often leads to synthesis , an extension and more complicated form of analysis. See our synthesis page for more information.

Example 1 of Analysis

Without analysis.

Embryonic stem cell research uses the stem cells from an embryo, causing much ethical debate in the scientific and political communities (Robinson, 2011). "Politicians don't know science" (James, 2010, p. 24). Academic discussion of both should continue (Robinson, 2011).

With Analysis (Added in Bold)

Embryonic stem cell research uses the stem cells from an embryo, causing much ethical debate in the scientific and political communities (Robinson, 2011). However, many politicians use the issue to stir up unnecessary emotion on both sides of the issues. James (2010) explained that "politicians don't know science," (p. 24) so scientists should not be listening to politics. Instead, Robinson (2011) suggested that academic discussion of both embryonic and adult stem cell research should continue in order for scientists to best utilize their resources while being mindful of ethical challenges.

Note that in the first example, the reader cannot know how the quotation fits into the paragraph. Also, note that the word both was unclear. In the revision, however, that the writer clearly (a) explained the quotations as well as the source material, (b) introduced the information sufficiently, and (c) integrated the ideas into the paragraph.

Example 2 of Analysis

Trow (1939) measured the effects of emotional responses on learning and found that student memorization dropped greatly with the introduction of a clock. Errors increased even more when intellectual inferiority regarding grades became a factor (Trow, 1939). The group that was allowed to learn free of restrictions from grades and time limits performed better on all tasks (Trow, 1939).

In this example, the author has successfully paraphrased the key findings from a study. However, there is no conclusion being drawn about those findings. Readers have a difficult time processing the evidence without some sort of ending explanation, an answer to the question so what? So what about this study? Why does it even matter?

Trow (1939) measured the effects of emotional responses on learning and found that student memorization dropped greatly with the introduction of a clock. Errors increased even more when intellectual inferiority regarding grades became a factor (Trow, 1939). The group that was allowed to learn free of restrictions from grades and time limits performed better on all tasks (Trow, 1939). Therefore, negative learning environments and students' emotional reactions can indeed hinder achievement.

Here the meaning becomes clear. The study’s findings support the claim the reader is making: that school environment affects achievement.

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Note that these videos were created while APA 6 was the style guide edition in use. There may be some examples of writing that have not been updated to APA 7 guidelines.

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Home / Guides / Citation Guides / MLA Format / How to Cite an Essay in MLA

How to Cite an Essay in MLA

The guidelines for citing an essay in MLA format are similar to those for citing a chapter in a book. Include the author of the essay, the title of the essay, the name of the collection if the essay belongs to one, the editor of the collection or other contributors, the publication information, and the page number(s).

Citing an Essay

Mla essay citation structure.

Last, First M. “Essay Title.” Collection Title, edited by First M. Last, Publisher, year published, page numbers. Website Title , URL (if applicable).

MLA Essay Citation Example

Gupta, Sanjay. “Balancing and Checking.” Essays on Modern Democracy, edited by Bob Towsky, Brook Stone Publishers, 1996, pp. 36-48. Essay Database, www . databaseforessays.org/modern/modern-democracy.

MLA Essay In-text Citation Structure

(Last Name Page #)

MLA Essay In-text Citation Example

Click here to cite an essay via an EasyBib citation form.

MLA Formatting Guide

MLA Formatting

• Annotated Bibliography
• Bibliography
• Block Quotes
• et al Usage
• In-text Citations
• Paraphrasing
• Page Numbers
• Sample Paper
• Works Cited
• MLA 8 Updates
• MLA 9 Updates
• View MLA Guide

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• Magazine Article
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• Website (no author)
• View all MLA Examples

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To cite your sources in an essay in MLA style, you need to have basic information including the author’s name(s), chapter title, book title, editor(s), publication year, publisher, and page numbers. The templates for in-text citations and a works-cited-list entry for essay sources and some examples are given below:

In-text citation template and example:

For citations in prose, use the first name and surname of the author on the first occurrence. For subsequent citations, use only the surname(s). In parenthetical citations, always use only the surname of the author(s).

Citation in prose:

First mention: Annette Wheeler Cafarelli

Subsequent occurrences: Wheeler Cafarelli

Parenthetical:

….(Wheeler Cafarelli).

Works-cited-list entry template and example:

The title of the chapter is enclosed in double quotation marks and uses title case. The book or collection title is given in italics and uses title case.

Surname, First Name. “Title of the Chapter.” Title of the Book , edited by Editor(s) Name, Publisher, Publication Year, page range.

Cafarelli, Annette Wheeler. “Rousseau and British Romanticism: Women and British Romanticism.” Cultural Interactions in the Romantic Age: Critical Essays in Comparative Literature , edited by Gregory Maertz. State U of New York P, 1998, pp. 125–56.

To cite an essay in MLA style, you need to have basic information including the author(s), the essay title, the book title, editor(s), publication year, publisher, and page numbers. The templates for citations in prose, parenthetical citations, and works-cited-list entries for an essay by multiple authors, and some examples, are given below:

For citations in prose, use the first name and surname of the author (e.g., Mary Strine).

For sources with two authors, use both full author names in prose (e.g., Mary Strine and Beth Radick).

For sources with three or more authors, use the first name and surname of the first author followed by “and others” or “and colleagues” (e.g., Mary Strine and others). In subsequent citations, use only the surname of the first author followed by “and others” or “and colleagues” (e.g., Strine and others).

In parenthetical citations, use only the author’s surname. For sources with two authors, use two surnames (e.g., Strine and Radick). For sources with three or more author names, use the first author’s surname followed by “et al.”

First mention: Mary Strine…

Subsequent mention: Strine…

First mention: Mary Strine and Beth Radick…

Subsequent mention: Strine and Radick…

First mention: Mary Strine and colleagues …. or Mary Strine and others

Subsequent occurrences: Strine and colleagues …. or Strine and others

…. (Strine).

….(Strine and Radick).

….(Strine et al.).

The title of the essay is enclosed in double quotation marks and uses title case. The book or collection title is given in italics and uses title case.

Surname, First Name, et al. “Title of the Essay.” Title of the Book , edited by Editor(s) Name, Publisher, Publication Year, page range.

Strine, Mary M., et al. “Research in Interpretation and Performance Studies: Trends, Issues, Priorities.” Speech Communication: Essays to Commemorate the 75th Anniversary of the Speech Communication Association , edited by Gerald M. Phillips and Julia T. Wood, Southern Illinois UP, 1990, pp. 181–204.

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In-Text Citations: The Basics

Welcome to the Purdue OWL

This page is brought to you by the OWL at Purdue University. When printing this page, you must include the entire legal notice.

Copyright ©1995-2018 by The Writing Lab & The OWL at Purdue and Purdue University. All rights reserved. This material may not be published, reproduced, broadcast, rewritten, or redistributed without permission. Use of this site constitutes acceptance of our terms and conditions of fair use.

Note:  This page reflects the latest version of the APA Publication Manual (i.e., APA 7), which released in October 2019. The equivalent resource for the older APA 6 style  can be found here .

Reference citations in text are covered on pages 261-268 of the Publication Manual. What follows are some general guidelines for referring to the works of others in your essay.

Note:  On pages 117-118, the Publication Manual suggests that authors of research papers should use the past tense or present perfect tense for signal phrases that occur in the literature review and procedure descriptions (for example, Jones (1998)  found  or Jones (1998)  has found ...). Contexts other than traditionally-structured research writing may permit the simple present tense (for example, Jones (1998)  finds ).

APA Citation Basics

When using APA format, follow the author-date method of in-text citation. This means that the author's last name and the year of publication for the source should appear in the text, like, for example, (Jones, 1998). One complete reference for each source should appear in the reference list at the end of the paper.

If you are referring to an idea from another work but  NOT  directly quoting the material, or making reference to an entire book, article or other work, you only have to make reference to the author and year of publication and not the page number in your in-text reference.

On the other hand, if you are directly quoting or borrowing from another work, you should include the page number at the end of the parenthetical citation. Use the abbreviation “p.” (for one page) or “pp.” (for multiple pages) before listing the page number(s). Use an en dash for page ranges. For example, you might write (Jones, 1998, p. 199) or (Jones, 1998, pp. 199–201). This information is reiterated below.

Regardless of how they are referenced, all sources that are cited in the text must appear in the reference list at the end of the paper.

In-text citation capitalization, quotes, and italics/underlining

• Always capitalize proper nouns, including author names and initials: D. Jones.
• If you refer to the title of a source within your paper, capitalize all words that are four letters long or greater within the title of a source:  Permanence and Change . Exceptions apply to short words that are verbs, nouns, pronouns, adjectives, and adverbs:  Writing New Media ,  There Is Nothing Left to Lose .

( Note:  in your References list, only the first word of a title will be capitalized:  Writing new media .)

• When capitalizing titles, capitalize both words in a hyphenated compound word:  Natural-Born Cyborgs .
• Capitalize the first word after a dash or colon: "Defining Film Rhetoric: The Case of Hitchcock's  Vertigo ."
• If the title of the work is italicized in your reference list, italicize it and use title case capitalization in the text:  The Closing of the American Mind ;  The Wizard of Oz ;  Friends .
• If the title of the work is not italicized in your reference list, use double quotation marks and title case capitalization (even though the reference list uses sentence case): "Multimedia Narration: Constructing Possible Worlds;" "The One Where Chandler Can't Cry."

Short quotations

If you are directly quoting from a work, you will need to include the author, year of publication, and page number for the reference (preceded by "p." for a single page and “pp.” for a span of multiple pages, with the page numbers separated by an en dash).

You can introduce the quotation with a signal phrase that includes the author's last name followed by the date of publication in parentheses.

If you do not include the author’s name in the text of the sentence, place the author's last name, the year of publication, and the page number in parentheses after the quotation.

Long quotations

Place direct quotations that are 40 words or longer in a free-standing block of typewritten lines and omit quotation marks. Start the quotation on a new line, indented 1/2 inch from the left margin, i.e., in the same place you would begin a new paragraph. Type the entire quotation on the new margin, and indent the first line of any subsequent paragraph within the quotation 1/2 inch from the new margin. Maintain double-spacing throughout, but do not add an extra blank line before or after it. The parenthetical citation should come after the closing punctuation mark.

Because block quotation formatting is difficult for us to replicate in the OWL's content management system, we have simply provided a screenshot of a generic example below.

Formatting example for block quotations in APA 7 style.

Quotations from sources without pages

Direct quotations from sources that do not contain pages should not reference a page number. Instead, you may reference another logical identifying element: a paragraph, a chapter number, a section number, a table number, or something else. Older works (like religious texts) can also incorporate special location identifiers like verse numbers. In short: pick a substitute for page numbers that makes sense for your source.

Summary or paraphrase

If you are paraphrasing an idea from another work, you only have to make reference to the author and year of publication in your in-text reference and may omit the page numbers. APA guidelines, however, do encourage including a page range for a summary or paraphrase when it will help the reader find the information in a longer work. 

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How to Introduce Evidence in an Essay

Last Updated: December 5, 2023

This article was co-authored by Tristen Bonacci . Tristen Bonacci is a Licensed English Teacher with more than 20 years of experience. Tristen has taught in both the United States and overseas. She specializes in teaching in a secondary education environment and sharing wisdom with others, no matter the environment. Tristen holds a BA in English Literature from The University of Colorado and an MEd from The University of Phoenix. This article has been viewed 237,366 times.

When well integrated into your argument, evidence helps prove that you've done your research and thought critically about your topic. But what's the best way to introduce evidence so it feels seamless and has the highest impact? There are actually quite a few effective strategies you can use, and we've rounded up the best ones for you here. Try some of the tips below to introduce evidence in your essay and make a persuasive argument.

Setting up the Evidence

• You can use 1-2 sentences to set up the evidence, if needed, but usually more concise you are, the better.

• For example, you may make an argument like, “Desire is a complicated, confusing emotion that causes pain to others.”
• Or you may make an assertion like, “The treatment of addiction must consider root cause issues like mental health and poor living conditions.”

• For example, you may write, “The novel explores the theme of adolescent love and desire.”
• Or you may write, “Many studies show that addiction is a mental health issue.”

Putting in the Evidence

• For example, you may use an introductory clause like, “According to Anne Carson…”, "In the following chart...," “The author states…," "The survey shows...." or “The study argues…”
• Place a comma after the introductory clause if you are using a quote. For example, “According to Anne Carson, ‘Desire is no light thing" or "The study notes, 'levels of addiction rise as levels of poverty and homelessness also rise.'"
• A list of introductory clauses can be found here: https://student.unsw.edu.au/introducing-quotations-and-paraphrases .

• For example, you may write, “In the novel, Carson is never shy about how her characters express desire for each other: ‘When they made love/ Geryon liked to touch in slow succession each of the bones of Herakles' back…’”
• Or you may write, "The study charts the rise in addiction levels, concluding: 'There is a higher level of addiction in specific areas of the United States.'"

• For example, you may write, “Carson views events as inevitable, as man moving through time like “a harpoon,” much like the fates of her characters.”
• Or you may write, "The chart indicates the rising levels of addiction in young people, an "epidemic" that shows no sign of slowing down."

• For example, you may write in the first mention, “In Anne Carson’s The Autobiography of Red , the color red signifies desire, love, and monstrosity.” Or you may write, "In the study Addiction Rates conducted by the Harvard Review...".
• After the first mention, you can write, “Carson states…” or “The study explores…”.
• If you are citing the author’s name in-text as part of your citation style, you do not need to note their name in the text. You can just use the quote and then place the citation at the end.

• If you are paraphrasing a source, you may still use quotation marks around any text you are lifting directly from the source.

• For example, you may write, “In the novel, the characters express desire for each other: ‘When they made love/ Geryon liked to touch in slow succession each of the bones of Herakles' back (Carson, 48).”
• Or you may write, "Based on the data in the graph below, the study shows the 'intersection between opioid addiction and income' (Branson, 10)."
• If you are using footnotes or endnotes, make sure you use the appropriate citation for each piece of evidence you place in your essay.

• You may also mention the title of the work or source you are paraphrasing or summarizing and the author's name in the paraphrase or summary.
• For example, you may write a paraphrase like, "As noted in various studies, the correlation between addiction and mental illness is often ignored by medical health professionals (Deder, 10)."
• Or you may write a summary like, " The Autobiography of Red is an exploration of desire and love between strange beings, what critics have called a hybrid work that combines ancient meter with modern language (Zambreno, 15)."

• The only time you should place 2 pieces of evidence together is when you want to directly compare 2 short quotes (each less than 1 line long).
• Your analysis should then include a complete compare and contrast of the 2 quotes to show you have thought critically about them both.

Analyzing the Evidence

• For example, you may write, “In the novel, Carson is never shy about how her characters express desire for each other: ‘When they made love/ Geryon liked to touch in slow succession each of the bones of Herakles' back (Carson, 48). The connection between Geryon and Herakles is intimate and gentle, a love that connects the two characters in a physical and emotional way.”
• Or you may write, "In the study Addiction Rates conducted by the Harvard Review, the data shows a 50% rise in addiction levels in specific areas across the United States. The study illustrates a clear connection between addiction levels and communities where income falls below the poverty line and there is a housing shortage or crisis."

• For example, you may write, “Carson’s treatment of the relationship between Geryon and Herakles can be linked back to her approach to desire as a whole in the novel, which acts as both a catalyst and an impediment for her characters.”
• Or you may write, "The survey conducted by Dr. Paula Bronson, accompanied by a detailed academic dissertation, supports the argument that addiction is not a stand alone issue that can be addressed in isolation."

• For example, you may write, “The value of love between two people is not romanticized, but it is still considered essential, similar to the feeling of belonging, another key theme in the novel.”
• Or you may write, "There is clearly a need to reassess the current thinking around addiction and mental illness so the health and sciences community can better study these pressing issues."

Expert Q&A

You Might Also Like

• ↑ Tristen Bonacci. Licensed English Teacher. Expert Interview. 21 December 2021.
• ↑ https://writing.wisc.edu/handbook/assignments/quoliterature/
• ↑ https://writingcenter.unc.edu/tips-and-tools/evidence/
• ↑ https://wts.indiana.edu/writing-guides/using-evidence.html

About This Article

Before you introduce evidence into your essay, begin the paragraph with a topic sentence. This sentence should give the reader an overview of the point you’ll be arguing or making with the evidence. When you get to citing the evidence, begin the sentence with a clause like, “The study finds” or “According to Anne Carson.” You can also include a short quotation in the middle of a sentence without introducing it with a clause. Remember to introduce the author’s first and last name when you use the evidence for the first time. Afterwards, you can just mention their last name. Once you’ve presented the evidence, take time to explain in your own words how it backs up the point you’re making. For tips on how to reference your evidence correctly, keep reading! Did this summary help you? Yes No

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Citing Text Evidence in 6 Steps

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How ‘History and Tradition’ Rulings Are Changing American Law

A new legal standard is gaining traction among conservative judges — one that might turn back the clock on drag shows, gun restrictions and more.

Credit... Photo illustration by Ricardo Tomás

Supported by

By Emily Bazelon

Emily Bazelon is a staff writer for the magazine and the Truman Capote fellow for creative writing and law at Yale Law School. Her recent features on the Supreme Court have focused on its rightward lurch, its struggle with affirmative action and the political clashes over its power.

• April 29, 2024

In November 2022, a group of L.G.B.T.Q. students at West Texas A&M University started planning a drag show for the following spring. They wanted to raise money for suicide prevention and stand up for queer self-expression at a time when conservatives in Texas, in the name of protecting children, were mobilizing to shut drag shows down.

Listen to this article, read by Almarie Guerra de Wilson

The student group, Spectrum WT, set a few guidelines. The show would be “PG-13,” the students told the university. Kids under the age of 18 — the students had in mind the siblings of a performer — could come only if they were accompanied by a parent or guardian.

Despite this plan, the president of West Texas A&M, Walter Wendler, announced in March 2023 that he was barring the event from campus. In a statement on his personal website, Wendler called drag shows “derisive, divisive and demoralizing misogyny.” Spectrum WT sued, arguing that Wendler’s decision to cancel the show was a “textbook” example of discriminating against speech based on viewpoint.

Legally speaking, Spectrum WT had a strong case. Since the 1970s, the Supreme Court has ruled that the First Amendment protects speech on public university campuses, “no matter how offensive” and despite “conventions of decency,” as two decisions put it. Wendler acknowledged that he was refusing to allow the drag show to take place “even when the law of the land appears to require it.”

But the lawsuit landed on the docket of Judge Matthew J. Kacsmaryk, a Trump appointee to the federal bench in Amarillo who is the author of several sweeping arch-conservative rulings. And in the drag-show case, Judge Kacsmaryk had a new tool, supplied by the Supreme Court. Known as the “history and tradition” test, the legal standard has been recently adopted by the court’s conservative majority to allow judges to set aside modern developments in the law to restore the precedents of the distant past.

The conservative justices applied the history-and-tradition test in three major rulings decided in the space of a week in June 2022. First, they struck down a New York restriction on gun ownership for being out of line with the nation’s “historical tradition” around regulating guns. Next, in Dobbs v. Jackson Women’s Health Organization, a conservative majority ended the constitutional right to abortion in Roe v. Wade because it was not “deeply rooted in the Nation’s history and tradition.” Finally, the court held that a public high school’s decision to let go of a football coach for praying with a crowd he gathered at midfield was out of line with “historical practices and understandings” of religious freedom.

The flurry of history-and-tradition opinions prompted an uproar among liberal court-watchers. What counted as historical or traditional? The open-ended nature of the terms seemed to invite a freewheeling survey of the 18th and 19th centuries. It’s “basically a fancy way of saying, ‘if men in power didn’t recognize this right as fundamental in ye olde times, we won’t recognize it now,’” tweeted Joseph Fishkin, a law professor at the University of California, Los Angeles. The court was playing “memory games,” in the words of a widely cited law review article about Dobbs by Reva Siegel, a Yale law professor. Why does the conservative majority “appeal to history and tradition in exactly those cases in which it is changing the law?” she asked in another, forthcoming piece.

Some judges expressed practical concerns as well. In one of many recent suits that involved challenges to state and federal gun restrictions, Judge Carlton Reeves, an Obama nominee to the federal bench in Mississippi, pointed out that judges were not trained to sort through the competing interpretations of history. “We are not experts in what white, wealthy and male property owners thought about firearms regulation in 1791,” Reeves wrote.

Conservatives, meanwhile, had their own furious debate. For them, a central question was whether the Supreme Court’s conservative majority was deviating from originalism, the method of interpreting the Constitution championed since the 1980s by heroes of the right like former Justice Antonin Scalia. Originalism resembles the history-and-tradition test in focusing on the past. But its main selling point was to fix the meaning of the Constitution to the moment in which it was written, to prevent judges from substituting their values for the wisdom of the nation’s founders.

Though originalism in practice never lived up to this promise , because judges used it inconsistently or to reach the results they preferred, “history and tradition,” unlatched from any one moment, is even more pliable and indeterminate. It lets judges choose from a vast array of sources, which makes it easy to cherry-pick.

Skeptics of the history-and-tradition standard received some validation from an unlikely source. At a talk at Catholic University’s law school in September 2023, Justice Amy Coney Barrett, a former Scalia clerk who joined Alito’s opinion in Dobbs, used an old saying to warn that a judge’s hunt for historical sources could be like “looking over a crowd and picking out your friends.”

That same day, Judge Kacsmaryk issued his opinion about the student drag show. Citing the Supreme Court’s approach to history in the 2022 gun case, Kacsmaryk said that the early history of the First Amendment is “drastically different” than the modern version. Kacsmaryk cited an 18th-century treatise describing the government’s power to censure “licentiousness” and a 19th-century ban on mailing “lascivious” materials. Older rules like these continue to set an “outer limit” on “ sexualized ‘expressive conduct,’” Kacsmaryk wrote. He ruled that the university could bar the drag show — an extraordinary and anti-modern result.

In March, the Supreme Court rejected the student group’s request to hold a second annual drag show on campus. Kacsmaryk’s decision is now pending at the U.S. Court of Appeals for the Fifth Circuit. Also unresolved is a larger question: How much will the scope of American liberty change as conservative judges impose the past on the present?

Justice Samuel Alito, the author of the majority opinion in Dobbs, has called himself a “practical originalist,” a phrase that fits his record of putting results above theory. In Dobbs, he used the history-and-tradition test to solve a problem that originalism posed for abortion opponents: When the Constitution was written, and long afterward, courts in the United States followed English common law, a set of rules and precedents developed by judges that widely permitted abortion in early pregnancy.

For centuries, before pregnancy tests, many people believed that fetal life began with “quickening,” when women felt the first fetal movement, usually between 15 and 18 weeks. Early American law did not even recognize an abortion as having occurred before that stage, according to a friend-of-the-court brief in Dobbs submitted by the American Historical Association and the Organization of American Historians.

In 1973, when the Supreme Court decided Roe, Justice Harry Blackmun, in his majority opinion, contrasted this early history with more recent state restrictions. “At the time of the adoption of our Constitution, and throughout the major portion of the 19th century, abortion was viewed with less disfavor,” Blackmun wrote. “A woman enjoyed a substantially broader right to terminate a pregnancy than she does in most States today.”

Blackmun, who was not an originalist, did not feel bound by the distant past. He treated history in Roe as “a resource, not a command,” as Jack Balkin, a Yale law professor, has written in his new book, “Memory and Authority,” describing how lawyers often use historical facts. This approach to the past — as relevant but not determinative — “was the major form of constitutional interpretation,” says Robert Post, author of the recent book “The Taft Court.” “History was never a simple fact to be ascertained. It was always an interpretation of the meaning of widespread practices.”

The cornerstone Blackmun laid for the constitutional right to abortion came from the 14th Amendment, which Congress ratified in 1868 during Reconstruction. As one clause of the amendment states, “nor shall any State deprive any person of life, liberty, or property, without due process of law.” Interpreting those words a century later, the court said that the 14th Amendment’s concept of liberty, in the due-process clause, included a right to privacy. In Roe, Blackmun said the right to privacy was “broad enough to encompass a woman’s decision whether or not to terminate her pregnancy.”

Since then, majorities made up of liberals and conservatives have turned to the due-process clause as the basis for adapting the Constitution to modern social conditions, recognizing new rights including parental authority and sexual liberties. Anthony Kennedy, a Reagan nominee, took the lead. “The generations that wrote and ratified the Bill of Rights and the 14th Amendment did not presume to know the extent of freedom in all of its dimensions,” Kennedy wrote in his landmark 2015 majority opinion providing for the right to same-sex marriage, in the case Obergefell v. Hodges, “and so they entrusted to future generations a charter protecting the right of all persons to enjoy liberty as we learn its meaning.”

In Dobbs, however, Alito called the court’s reliance on the due-process clause in abortion cases “controversial.” He stopped short of declaring it invalid, which would jettison too many modern rights and freedoms, like sweeping all the pieces off a chess board. (Only Justice Clarence Thomas, in a concurrence no one else joined, called for such a reconsideration.)

Alito aimed to topple the right to abortion and only that right. Using the history-and-tradition test, he purported to show that legal abortion was not “deeply rooted” in the nation’s history, claiming that “an unbroken tradition of prohibiting abortion on pain of criminal punishment persisted from the earliest days of the common law until 1973.” But Alito didn’t acknowledge that in the rare known cases in which someone was convicted of causing an abortion up to the Civil War, it was almost always after quickening. And “such abortion providers came to public notice not because of their practice per se but if the pregnant woman had suffered badly or died as a result,” says Nancy Cott, an emerita professor of history at Harvard.

Alito also made this key claim: “By 1868, the year when the 14th Amendment was ratified, three-quarters of the States, 28 out of 37, had enacted statutes making abortion a crime even if it was performed before quickening.” But according to Aaron Tang, a law professor at the University of California, Davis, that number is inflated. “Substantial evidence suggests that as many as 12 of the 28 states” continued to permit abortions before quickening, Tang wrote in a 2023 article in The Stanford Law Review.

Alito then pointed out more abortion restrictions through 1910, ignoring other moments in history, including steps some states took before and after Roe, to ensure that abortion would be legal within their borders under certain circumstances. He also relied on a 1997 case, in which the court refused to extend its concept of liberty based on the due process clause to include physician-assisted suicide, because it had “no place in our Nation’s traditions.” It was hard not to think that Alito was, as Justice Barrett put it, looking out over the crowd for his friends.

The history-and-tradition test could have even more far-reaching effects on other areas of law. Last year, for example, the U.S. Court of Appeals for the Sixth Circuit considered a challenge to Tennessee’s ban on gender-related medical treatments for minors, brought by parents who argued that they had a 14th Amendment right to make decisions about treatments on their children’s behalf. In the majority opinion of a three-judge panel, Judge Jeffrey Sutton agreed that parents have the right to make decisions “concerning the care, custody and control of their children” — but ruled against the parents, because they hadn’t shown that a right to new medical treatments was “rooted in the nation’s history and tradition.” A month later, another federal appeals court similarly upheld an Alabama ban on gender-related care for minors.

Applied literally, the history-and-tradition test turns on whether a new practice is like an old one. If not, courts can discount whatever modern goal it is supposed to serve. But some of the justices are already wrestling with whether they have painted themselves into a corner.

The dilemma was evident at the oral argument in November for United States v. Rahimi, a case about the intersecting dangers of guns and domestic violence. In 2021, Zackey Rahimi was arrested for having a gun, which put him in violation of a 1994 federal law that made it a crime for someone to possess a firearm if subject to a protective order for threatening a spouse or partner. The rationale for the law, which many states have versions of, is that women who live with abusers are far more likely to be murdered if their partners have access to a gun. A Texas judge granted Rahimi’s ex-girlfriend a protective order in 2020 after she said Rahimi threw her to the ground, dragged her to his car and slammed her head against the dashboard. Months later, Rahimi went on a shooting spree, which included firing at another driver after a car accident, prompting police to search his home and find his guns.

But using the history-and-tradition test, the U.S. Court of Appeals for the Fifth Circuit reversed Rahimi’s conviction for illegal gun possession. The conservative appeals court struck down the 1994 law for being a historical outlier “that our ancestors would never have accepted” and thus invalid under the Second Amendment. The past governed the present, in the view of the Fifth Circuit. At the Supreme Court, the Biden administration was forced to defend the 1994 law according to the terms of the history-and-tradition test. (A decision is expected by the end of June.) The government argued that the statute fit into a general tradition, throughout American history, of disarming people who were considered dangerous.

But for much of American history, women, who could not vote, had little recourse when their family members harmed them. And the groups the government disarmed had nothing in common with domestic-violence offenders. They included enslaved people and Native Americans. The Biden administration disavowed these examples, calling them “odious” because they were based on race. That left historical examples that were also not analogous — like British loyalists and Confederate rebels.

Some conservative justices seemed to search for a way to allow the government to disarm domestic-violence offenders. “The legislature can make judgments to disarm people consistently with the Second Amendment based on dangerousness,” Justice Barrett suggested.

Now it seemed as if the history-and-tradition test were flexible — not really a command at all. Justice Ketanji Brown Jackson, a liberal, used the argument to reflect on the inconsistency. “If we’re still applying modern sensibilities, I don’t really understand the historical framing,” Jackson said. She was exposing the trap the Supreme Court has set for itself and the lower courts. Either the past, however archaic, retains real command over the present, or the history-and-tradition test is no test at all.

Read by Almarie Guerra de Wilson

Narration produced by Krish Seenivasan

Engineered by Lance Neal

Source photos: Harris & Ewing/Library of Congress; Erin Schaff/The New York Times.

Emily Bazelon is a staff writer at The New York Times Magazine. More about Emily Bazelon

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Deciphering the Family Tree of Moses: Biblical Perspectives

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Opinion Here’s why Uri Berliner couldn’t stay at NPR

Uri Berliner is offended.

In an April 9 essay in the Free Press, Berliner, who worked at NPR for 25 years, raps his employer for allegedly running a newsroom fueled by progressive sensibilities that seep into a skewed on-air product. Stories on Trump-Russia, Hunter Biden and covid-19 have all suffered from acute NPRitis, he writes. And racial and identity considerations — as well as affinity groups — shape workplace culture.

The essay triggered a bona fide media drama that concluded on Wednesday with Berliner’s resignation. On his way out, he delivered a parting shot at CEO Katherine Maher. “I cannot work in a newsroom where I am disparaged by a new C.E.O. whose divisive views confirm the very problems at NPR I cite in my Free Press essay,” Berliner wrote on X .

Just what had Maher done to deserve such a diss? She had published a statement pushing back against Berliner’s essay : “Questioning whether our people are serving our mission with integrity, based on little more than the recognition of their identity, is profoundly disrespectful, hurtful, and demeaning.” As NPR’s own David Folkenflik reported, Berliner took exception to that commentary.

Which is to say, Berliner is now an expert in disparagement and umbrage. In his Free Press essay, he deplores his colleagues’ “advocacy” and alleges that it had “veered toward efforts to damage or topple [Donald] Trump’s presidency.”

Now that is disparagement. Even in the rough-and-tumble world of journalism, slamming your colleagues for their published work — especially in another outlet — is a rare undertaking. As Berliner suggests in his essay, it was something of a last resort, considering that he had raised his concerns internally to little effect. He invited people to sample NPR’s coverage and “make their own judgment.”

Invitation accepted. Over the past several days, I have sifted through roughly three years’ worth of NPR’s coverage of Russiagate, the effort by federal investigators and the media to discover the truth about the Trump campaign’s connections to Russia. Since NPR’s alleged tilt on this story serves as Exhibit No. 1 in Berliner’s onslaught — and since it’s central to the claim that the network sought to topple Trump — I chose to limit my efforts to this portion of the essay.

And what a portion it is! The NPR Russia-Trump coverage plume under fire from Berliner consists of thousands of articles, podcasts, segments and so on. Berliner links to one . His serious allegations, accordingly, are backed by scant evidence, if any at all. It’s a lazy, summary approach to evaluating a large body of work — a feelings-based critique of the sort that passes for media reporting these days. Too often, essayists write their conclusory broadsides against this or that outlet, confident in the knowledge that their fellow ideological travelers will applaud no matter how threadbare the supporting material.

Berliner’s opus was published by the Free Press , an outlet dedicated to covering stories “ignored or misconstrued in the service of an ideological narrative” — and not by NPR, which requires infinitely greater substantiation for its media reporting, whether the crisis lies in its own newsroom or somewhere else.

The irony there: Berliner has edited many of the stories carrying the byline of Folkenflik, NPR’s media correspondent. He knows better.

Here’s how Berliner supports his conclusions on NPR’s Russia work: Rep. Adam “Schiff, who was the top Democrat on the House Intelligence Committee, became NPR’s guiding hand, its ever-present muse. By my count, NPR hosts interviewed Schiff 25 times about Trump and Russia. During many of those conversations, Schiff alluded to purported evidence of collusion. The Schiff talking points became the drumbeat of NPR news reports.”

Yes, Schiff is a recurring presence in the broadcasts. “Like many broadcast news organizations, NPR interviewed Rep. Schiff often during the Trump administration, as he was a principal figure in the Russian interference investigation — a story we covered with caution and perspective,” says an NPR spokesperson in a statement. “Rep. Schiff’s perspective was only one element of our coverage of the Russian interference story, in no way did he commandeer the reporting of NPR.” According to the spokesperson, NPR did 900 interviews with congressional lawmakers between January 2017 and December 2019 — including Paul Ryan , Jim Jordan , Eric Swalwell and others.

Numbers matter less than the content of those Schiff interviews, which tend toward procedural mishmash, recitation of previously reported revelations and the centrality of oversight. In this interview , Schiff says that if former Trump campaign chairman Paul Manafort cooperates with authorities, “we could learn a lot more.” In this one , the congressman speaks to his committee’s investigative imperatives: “I think we need to use subpoenas, and we need to stand up and say, we’re going to get the answers here.” In this one , Schiff is asked whether Trump gets “especially agitated” when the topic turns to Russia. “Well, absolutely,” he responds.

Is this the prejudicial poison of which Berliner writes? I asked him to supply instances in which Schiff’s talking points suffused NPR’s independent reporting. After several emails and a phone call, Berliner hasn’t responded with supporting material.

Had NPR wished to addle its lefty audience with suggestive reporting about Trump’s alleged criminality regarding Russia, it had a tool at its disposal. The so-called Steele dossier, published in early January 2017 by BuzzFeed News, contained explosive allegations presented by a former British intelligence officer. Various news outlets and commentators bathed the dossier in credibility it didn’t deserve, as noted in an extensive thread by Drew Holden and a series in this space . Top offenders include McClatchy, which ran stories bolstering the dossier’s claims that former Trump lawyer Michael Cohen had traveled to Prague for collusive business; and dossier believer in chief Rachel Maddow of MSNBC, who cheered for the document throughout Russiagate.

NPR’s dossier work was by no means perfect. “Fresh Air” host Terry Gross, for example, occasionally failed to properly smack down dossier boosters during interviews. Yet the outlet was careful to avoid McClatchy’s “scoops” on Cohen and otherwise to cordon off its descriptions of the dossier with police tape. “NPR has never detailed the document because so much of it remains unproved,” reads a 2019 NPR story . The NPR spokesperson said in a statement: “We were not able to find any examples of NPR corroborating unconfirmed elements of the Trump dossier."

As further evidence of his employer’s errant ways, Berliner argues that after the Mueller report found “no credible evidence of collusion, NPR’s coverage was notably sparse. Russiagate quietly faded from our programming.” It’s an immutable law of media physics, of course, that coverage peters out when a story comes to an end. Who, after all, is doing continuing coverage of Abscam these days?

But there’s more flimsiness afoot here. Berliner’s dismissal of Robert S. Mueller III’s findings — technically misguided, because the special counsel’s investigation didn’t apply the “concept of 'collusion’” in its work — leaves the impression that the media’s pursuit of the various Russiagate strands was a fool’s errand. In fact, journalists as well as official investigations documented a spreadsheet’s worth of scandalous activity that didn’t amount to an international conspiracy, in Mueller’s view. Trump will have you believe that the absence of criminality signifies the absence of wrongdoing, a logical atrocity abetted by Berliner’s essay.

Ditching the nitty-gritty, Berliner’s claim of an NPR campaign to “topple” Trump grinds against the measured claims in NPR’s day-to-day coverage. Examples abound. In this segment , NPR correspondents struggle to wrap their heads around the just-released Mueller report. In this one , NPR’s Mary Louise Kelly interviews a former CIA official who presciently shoots down liberal fever dreams related to Russia and Trump. In this piece , published months before the Mueller report, an NPR editor argues that the Russia case is “weakening” and even attributes an “important kernel of truth” to the famous tweet by Trump citing “No Smocking Gun … No Collusion.” This piece highlights Trump’s point of view regarding the Mueller investigation. And this one bears the headline “Trumps Exult Following Reports Of No Phone Contact Ahead Of 2016 Russia Meeting.”

After the Russia experience, writes Berliner, NPR compounded its mistakes by moving on with “no mea culpas, no self-reflection.” By all means, self-reflect — it’s a good step for any news organization after a big story. Presumably, Berliner would have supplied various URLs for such a review, but he didn’t share any with me. After skulking around in the NPR search box, I’d nominate the Gross interviews on the dossier and other pieces that faced challenges or turned out to be inconsistent with other reporting.

With his tendentious claims, however, Berliner doesn’t merely overstep the paltry evidence in his piece. He positions his now-former workplace as a hive of ideologues driven by political outcomes instead of the facts — basically a left-wing analogue to Fox News. That salvo appeared to diminish his appeal as a newsroom collaborator.

NPR, as it turns out, is an analogue to nothing — a sui generis outlet driven by old-fashioned journo-principles, an aversion to offending anyone and a steady propensity to annoy listeners. Surely, it has many things to apologize for, though an on-air campaign to oust a president isn’t among them.

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