how to harvard reference a website in an essay

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Quick guide to Harvard referencing (Cite Them Right)

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There are different versions of the Harvard referencing style. This guide is a quick introduction to the commonly-used Cite Them Right version. You will find further guidance available through the OU Library on the Cite Them Right Database .

For help and support with referencing and the full Cite Them Right guide, have a look at the Library’s page on referencing and plagiarism . If you need guidance referencing OU module material you can check out which sections of Cite Them Right are recommended when referencing physical and online module material .

This guide does not apply to OU Law undergraduate students . If you are studying a module beginning with W1xx, W2xx or W3xx, you should refer to the Quick guide to Cite Them Right referencing for Law modules .

Table of contents

In-text citations and full references.

• Secondary referencing
• Page numbers
• Citing multiple sources published in the same year by the same author

Full reference examples

Referencing consists of two elements:

• in-text citations, which are inserted in the body of your text and are included in the word count. An in-text citation gives the author(s) and publication date of a source you are referring to. If the publication date is not given, the phrase 'no date' is used instead of a date. If using direct quotations or you refer to a specific section in the source you also need the page number/s if available, or paragraph number for web pages.
• full references, which are given in alphabetical order in reference list at the end of your work and are not included in the word count. Full references give full bibliographical information for all the sources you have referred to in the body of your text.

To see a reference list and intext citations check out this example assignment on Cite Them Right .

Difference between reference list and bibliography

a reference list only includes sources you have referred to in the body of your text

a bibliography includes sources you have referred to in the body of your text AND sources that were part of your background reading that you did not use in your assignment

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Examples of in-text citations

You need to include an in-text citation wherever you quote or paraphrase from a source. An in-text citation consists of the last name of the author(s), the year of publication, and a page number if relevant. There are a number of ways of incorporating in-text citations into your work - some examples are provided below. Alternatively you can see examples of setting out in-text citations in Cite Them Right .

Note: When referencing a chapter of an edited book, your in-text citation should give the author(s) of the chapter.

Online module materials

(Includes written online module activities, audio-visual material such as online tutorials, recordings or videos).

When referencing material from module websites, the date of publication is the year you started studying the module.

Surname, Initial. (Year of publication/presentation) 'Title of item'. Module code: Module title . Available at: URL of VLE (Accessed: date).

OR, if there is no named author:

The Open University (Year of publication/presentation) 'Title of item'. Module code: Module title . Available at: URL of VLE (Accessed: date).

Rietdorf, K. and Bootman, M. (2022) 'Topic 3: Rare diseases'. S290: Investigating human health and disease . Available at: https://learn2.open.ac.uk/mod/oucontent/view.php?id=1967195 (Accessed: 24 January 2023).

The Open University (2022) ‘3.1 The purposes of childhood and youth research’. EK313: Issues in research with children and young people . Available at: https://learn2.open.ac.uk/mod/oucontent/view.php?id=1949633&section=1.3 (Accessed: 24 January 2023).

You can also use this template to reference videos and audio that are hosted on your module website:

The Open University (2022) ‘Video 2.7 An example of a Frith-Happé animation’. SK298: Brain, mind and mental health . Available at: https://learn2.open.ac.uk/mod/oucontent/view.php?id=2013014&section=4.9.6 (Accessed: 22 November 2022).

The Open University (2022) ‘Audio 2 Interview with Richard Sorabji (Part 2)’. A113: Revolutions . Available at: https://learn2.open.ac.uk/mod/oucontent/view.php?id=1960941&section=5.6 (Accessed: 22 November 2022).

Note: if a complete journal article has been uploaded to a module website, or if you have seen an article referred to on the website and then accessed the original version, reference the original journal article, and do not mention the module materials. If only an extract from an article is included in your module materials that you want to reference, you should use secondary referencing, with the module materials as the 'cited in' source, as described above.

Surname, Initial. (Year of publication) 'Title of message', Title of discussion board , in Module code: Module title . Available at: URL of VLE (Accessed: date).

Fitzpatrick, M. (2022) ‘A215 - presentation of TMAs', Tutor group discussion & Workbook activities , in A215: Creative writing . Available at: https://learn2.open.ac.uk/mod/forumng/discuss.php?d=4209566 (Accessed: 24 January 2022).

Note: When an ebook looks like a printed book, with publication details and pagination, reference as a printed book.

Surname, Initial. (Year of publication) Title . Edition if later than first. Place of publication: publisher. Series and volume number if relevant.

For ebooks that do not contain print publication details

Surname, Initial. (Year of publication) Title of book . Available at: DOI or URL (Accessed: date).

Example with one author:

Bell, J. (2014) Doing your research project . Maidenhead: Open University Press.

Adams, D. (1979) The hitchhiker's guide to the galaxy . Available at: http://www.amazon.co.uk/kindle-ebooks (Accessed: 23 June 2021).

Example with two or three authors:

Goddard, J. and Barrett, S. (2015) The health needs of young people leaving care . Norwich: University of East Anglia, School of Social Work and Psychosocial Studies.

Example with four or more authors:

Young, H.D. et al. (2015) Sears and Zemansky's university physics . San Francisco, CA: Addison-Wesley.

Note: You can choose one or other method to reference four or more authors (unless your School requires you to name all authors in your reference list) and your approach should be consistent.

Note: Books that have an editor, or editors, where each chapter is written by a different author or authors.

Surname of chapter author, Initial. (Year of publication) 'Title of chapter or section', in Initial. Surname of book editor (ed.) Title of book . Place of publication: publisher, Page reference.

Franklin, A.W. (2012) 'Management of the problem', in S.M. Smith (ed.) The maltreatment of children . Lancaster: MTP, pp. 83–95.

Surname, Initial. (Year of publication) 'Title of article', Title of Journal , volume number (issue number), page reference.

If accessed online:

Surname, Initial. (Year of publication) 'Title of article', Title of Journal , volume number (issue number), page reference. Available at: DOI or URL (if required) (Accessed: date).

Shirazi, T. (2010) 'Successful teaching placements in secondary schools: achieving QTS practical handbooks', European Journal of Teacher Education , 33(3), pp. 323–326.

Shirazi, T. (2010) 'Successful teaching placements in secondary schools: achieving QTS practical handbooks', European Journal of Teacher Education , 33(3), pp. 323–326. Available at: https://libezproxy.open.ac.uk/login?url=https://search.ebscohost.com/log... (Accessed: 27 January 2023).

Barke, M. and Mowl, G. (2016) 'Málaga – a failed resort of the early twentieth century?', Journal of Tourism History , 2(3), pp. 187–212. Available at: https://doi.org/10.1080/1755182X.2010.523145

Surname, Initial. (Year of publication) 'Title of article', Title of Newspaper , Day and month, Page reference.

Surname, Initial. (Year of publication) 'Title of article', Title of Newspaper , Day and month, Page reference if available. Available at: URL (Accessed: date).

Mansell, W. and Bloom, A. (2012) ‘£10,000 carrot to tempt physics experts’, The Guardian , 20 June, p. 5.

Roberts, D. and Ackerman, S. (2013) 'US draft resolution allows Obama 90 days for military action against Syria', The Guardian , 4 September. Available at: http://www.theguardian.com/world/2013/sep/04/syria-strikes-draft-resolut... (Accessed: 9 September 2015).

Surname, Initial. (Year that the site was published/last updated) Title of web page . Available at: URL (Accessed: date).

Organisation (Year that the page was last updated) Title of web page . Available at: URL (Accessed: date).

Robinson, J. (2007) Social variation across the UK . Available at: https://www.bl.uk/british-accents-and-dialects/articles/social-variation... (Accessed: 21 November 2021).

The British Psychological Society (2018) Code of Ethics and Conduct . Available at: https://www.bps.org.uk/news-and-policy/bps-code-ethics-and-conduct (Accessed: 22 March 2019).

Note: Cite Them Right Online offers guidance for referencing webpages that do not include authors' names and dates. However, be extra vigilant about the suitability of such webpages.

Surname, Initial. (Year) Title of photograph . Available at: URL (Accessed: date).

Kitton, J. (2013) Golden sunset . Available at: https://www.jameskittophotography.co.uk/photo_8692150.html (Accessed: 21 November 2021).

stanitsa_dance (2021) Cossack dance ensemble . Available at: https://www.instagram.com/p/COI_slphWJ_/ (Accessed: 13 June 2023).

Note: If no title can be found then replace it with a short description.

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• Writing Tips

Harvard Referencing – How to Cite a Website

2-minute read

• 5th July 2016

In our modern, digital world, it’s no surprise that students often go online before heading to the library when researching an essay.

However, no matter how study methods change, clearly referencing sources will always be essential.

But citing a website isn’t quite the same as citing a book, since you need to provide different information in the reference list. To help out, we’ve prepared this quick guide on how to cite a website using Harvard referencing.

In-Text Citations

The basics of Harvard citations for websites are the same as for a book, requiring you to give the author surname and year of publication in parentheses:

The internet allows you to find information quickly (Moxley, 2009).

The trouble is that finding the author name and year of publication can be tricky. Make sure to check carefully, but if you can’t find the information needed, you still have options.

Firstly, if you can’t find the individual author of an article , you can name an organisation:

The University of South Queensland (2016) says that citing sources is crucial to academic writing.

If this isn’t appropriate, you can give the page title in the citation instead:

Citing sources is a vital part of academic writing (Harvard citation style: Introduction, 2016).

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Secondly, if you can’t find the date of a website , you can use ‘n.d.’ (short for ‘no date’) instead:

Academic writing involves engaging with other people’s ideas (Victoria University, n.d.).

Any missing information should also be clearly indicated in the reference list, using the page title when no author is named and ‘n.d.’ when no date is available.

Reference List

The general format for a website in a Harvard reference list is:

Author Surname, Initial(s). (Year) Title of web page [Online]. Available at URL [Accessed date].

As such, the first source cited in the examples above would appear in the reference list as:

Moxley, J. M. (2009) Library and Internet Research [Online]. Available at http://writingcommons.org/open-text/information-literacy/library-and-internet-research/732-library-and-internet-research [Accessed 31 May 2016].

Remember, however, that Harvard referencing conventions sometimes differ from one university to the next, so check your style guide before setting to work.

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• Writing Tips

Harvard Referencing – How to Cite Websites

3-minute read

• 6th December 2016

With so much information now available online, it’s hardly surprising that most students end up citing websites in their academic work . But since most referencing systems focus on traditional sources like books and journals, knowing how to do this can be tricky.

Thus, to help out, we’ve prepared a quick guide to citing websites using Harvard referencing .

In-Text Citations (Named Author)

When citing a website, the information required for in-text citations is the author’s surname and a year of publication. For instance:

Rousseau converted to Catholicism in 1728 (Bertram, 2010).

Websites don’t have page numbers, so these aren’t required when quoting an online source. However, you could include a paragraph or section number (use ‘para.’ to signal a paragraph number or the ‘§’ symbol to denote a section):

According to Bertram (2010, § 2.1), Rousseau thought that morality is often displaced by ‘the impulse to dominate, oppress and exploit’.

In-Text Citations (No Named Author/Date)

When no author is named for a webpage, you can give an organisational author. This will usually be a company (e.g. Pepsi) or agency (e.g. the HMRC):

Tax avoidance often involves contrived transactions that serve no purpose other than exploiting legal loopholes (HMRC, 2016).

If no date of publication is available, use ‘n.d.’ to indicate this:

Moths are ‘an essential part of food chains’ (RSPB, n.d.).

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It can be hard to spot the author and publication date for websites, though, so make sure to check carefully before omitting this information.

The Reference List

As with any source used in your work, you should list all cited websites in the reference list at the end of your document. The information needed here is:

Author Surname, Initial(s). (Year/Date of Last Update) Title of web page [Online]. Available at URL [Accessed date].

The ‘date of update’ field only applies if the page has been updated since it was published, so don’t worry about this if no updates are listed. The date of access (i.e. the date you accessed the site) is required for all online sources, though.

In practice, the reference list entry for a website would look like this:

Bertram, C. (2010) Jean Jacques Rousseau [Online]. Available at plato.stanford.edu/entries/rousseau/ [Accessed 24 October 2016].

Of course, if a webpage is missing a named author or date of publication, you should indicate this in the reference list:

RSPB (n.d.) Grow Food for Moths [Online]. Available at https://ww2.rspb.org.uk/makeahomeforwildlife/givenatureahomeinyourgarden/gardenactivities/growfoodformoths/ [Accessed 19 September 2016].

A Quick Note on Harvard Referencing

Although ‘Harvard referencing’ is commonly used by UK universities, there are dozens of variations on the basic parenthetical citation system described here. As such, it’s crucial that you check your university’s style guide for advice on the correct version to use.

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• Bibliography Answers

How to cite a website in APA, MLA, or Harvard style

There are many different ways to cite a website, depending on which citation style you need to format it in.

 The easy way to cite a website in any citation style

Use our citation generator below to automatically cite a website in any style, including APA, MLA 7 and 8, and Harvard. Just select the style you need, copy the URL into the search box, and press search. We’ll do the rest.

 The manual way to cite a website

To cite a website by hand just follow the instructions below. For the 3 most popular styles–APA, MLA 8, and Harvard–this is as follows:

 In APA style

You need to locate these details for the website: page or article author, page or article title, website name, published date, access date, page URL (web address) .

• The author can typically be found on the page, but if there isn’t one listed you can use the website name in its place.
• The page title can be found near the top of the page, and you can also find it by hovering your mouse over the browser tab.
• The website name can usually be found in the web address or by looking for a logo or similar at the very top of the page.
• There often isn’t a publish date , but if there is it’ll be very close to the page title.
• The access date is the date you took information from the article (usually today).
• The page URL can be copied straight from the address bar of your browser and will start with either http:// or https://.

Then use this template, replacing the colored placeholders with the information you found on the page:

Author last name , author first name initial . ( published year , published month and day ). Page title . Retrieved accessed month and day , accessed year , from article URL .

The final formatted citation should look like this:

Ingle, S. (2018, February 11). Winter Olympics was hit by cyber-attack, officials confirm. Retrieved July 24, 2018, from https://www.theguardian.com/sport/2018/feb/11/winter-olympics-was-hit-by-cyber-attack-officials-confirm.

For a more comprehensive guide, including what to do when you can’t find certain details, have a look at our more in-depth guide to citing a website in APA format .

 In MLA 8 style

Here are the specific details you need to find on the page: page or article author, page or article title, website name, published date, access date, page URL (web address) .

Then use this template:

Author last name , author first name . “ Page title .” website name , published date day, month, year , page URL . Accessed accessed date day, month, year .

Ingle, Sean. “Winter Olympics Was Hit by Cyber-Attack, Officials Confirm.” The Guardian , 11 Feb. 2018, https://www.theguardian.com/sport/2018/feb/11/winter-olympics-was-hit-by-cyber-attack-officials-confirm. Accessed 13 July 2018.

For a more comprehensive guide, including what to do when you can’t find certain details, have a look at our more in-depth guide to citing a website in MLA 8 format .

 In Harvard style

First, find these details for the website: page or article author, page or article title, website name, published date, access date, page URL (web address) .

Author last name , author firstname initial ( published date year ). Page title . [online] website name . Available at: page URL [Accessed accessed date day, month, year ].

Ingle, S. (2018). Winter Olympics was hit by cyber-attack, officials confirm . [online] The Guardian. Available at: https://www.theguardian.com/sport/2018/feb/11/winter-olympics-was-hit-by-cyber-attack-officials-confirm [Accessed 13 Jul. 2018].

Daniel is a qualified librarian, former teacher, and citation expert. He has been contributing to MyBib since 2018.

Cite A Website in Harvard style

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• Select style:
• Archive material
• Chapter of an edited book
• Conference proceedings
• Dictionary entry
• Dissertation
• DVD, video, or film
• E-book or PDF
• Edited book
• Encyclopedia article
• Government publication
• Music or recording
• Online image or video
• Presentation
• Press release
• Religious text

Use the following template or our Harvard Referencing Generator to cite a website. For help with other source types, like books, PDFs, or websites, check out our other guides. To have your reference list or bibliography automatically made for you, try our free citation generator .

Reference list

Place this part in your bibliography or reference list at the end of your assignment.

In-text citation

Place this part right after the quote or reference to the source in your assignment.

Popular Harvard Citation Guides

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Other Harvard Citation Guides

• How to cite a Archive material in Harvard style
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• How to cite a E-book or PDF in Harvard style
• How to cite a Edited book in Harvard style
• How to cite a Email in Harvard style
• How to cite a Encyclopedia article in Harvard style
• How to cite a Government publication in Harvard style
• How to cite a Interview in Harvard style
• How to cite a Legislation in Harvard style
• How to cite a Magazine in Harvard style
• How to cite a Music or recording in Harvard style
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• How to cite a Podcast in Harvard style
• How to cite a Presentation or lecture in Harvard style
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• Harvard In-Text Citation | A Complete Guide & Examples

Harvard In-Text Citation | A Complete Guide & Examples

Published on 30 April 2020 by Jack Caulfield . Revised on 5 May 2022.

An in-text citation should appear wherever you quote or paraphrase a source in your writing, pointing your reader to the full reference .

In Harvard style , citations appear in brackets in the text. An in-text citation consists of the last name of the author,  the year of publication, and a page number if relevant.

Up to three authors are included in Harvard in-text citations. If there are four or more authors, the citation is shortened with et al .

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Table of contents

Including page numbers in citations, where to place harvard in-text citations, citing sources with missing information, frequently asked questions about harvard in-text citations.

When you quote directly from a source or paraphrase a specific passage, your in-text citation must include a page number to specify where the relevant passage is located.

Use ‘p.’ for a single page and ‘pp.’ for a page range:

• Meanwhile, another commentator asserts that the economy is ‘on the downturn’ (Singh, 2015, p. 13 ).
• Wilson (2015, pp. 12–14 ) makes an argument for the efficacy of the technique.

If you are summarising the general argument of a source or paraphrasing ideas that recur throughout the text, no page number is needed.

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When incorporating citations into your text, you can either name the author directly in the text or only include the author’s name in brackets.

Naming the author in the text

When you name the author in the sentence itself, the year and (if relevant) page number are typically given in brackets straight after the name:

Naming the author directly in your sentence is the best approach when you want to critique or comment on the source.

Naming the author in brackets

When you  you haven’t mentioned the author’s name in your sentence, include it inside the brackets. The citation is generally placed after the relevant quote or paraphrase, or at the end of the sentence, before the full stop:

Multiple citations can be included in one place, listed in order of publication year and separated by semicolons:

This type of citation is useful when you want to support a claim or summarise the overall findings of sources.

Common mistakes with in-text citations

In-text citations in brackets should not appear as the subject of your sentences. Anything that’s essential to the meaning of a sentence should be written outside the brackets:

• (Smith, 2019) argues that…
• Smith (2019) argues that…

Similarly, don’t repeat the author’s name in the bracketed citation and in the sentence itself:

• As Caulfield (Caulfield, 2020) writes…
• As Caulfield (2020) writes…

Sometimes you won’t have access to all the source information you need for an in-text citation. Here’s what to do if you’re missing the publication date, author’s name, or page numbers for a source.

If a source doesn’t list a clear publication date, as is sometimes the case with online sources or historical documents, replace the date with the words ‘no date’:

When it’s not clear who the author of a source is, you’ll sometimes be able to substitute a corporate author – the group or organisation responsible for the publication:

When there’s no corporate author to cite, you can use the title of the source in place of the author’s name:

No page numbers

If you quote from a source without page numbers, such as a website, you can just omit this information if it’s a short text – it should be easy enough to find the quote without it.

If you quote from a longer source without page numbers, it’s best to find an alternate location marker, such as a paragraph number or subheading, and include that:

A Harvard in-text citation should appear in brackets every time you quote, paraphrase, or refer to information from a source.

The citation can appear immediately after the quotation or paraphrase, or at the end of the sentence. If you’re quoting, place the citation outside of the quotation marks but before any other punctuation like a comma or full stop.

In Harvard referencing, up to three author names are included in an in-text citation or reference list entry. When there are four or more authors, include only the first, followed by ‘ et al. ’

In Harvard style , when you quote directly from a source that includes page numbers, your in-text citation must include a page number. For example: (Smith, 2014, p. 33).

You can also include page numbers to point the reader towards a passage that you paraphrased . If you refer to the general ideas or findings of the source as a whole, you don’t need to include a page number.

When you want to use a quote but can’t access the original source, you can cite it indirectly. In the in-text citation , first mention the source you want to refer to, and then the source in which you found it. For example:

It’s advisable to avoid indirect citations wherever possible, because they suggest you don’t have full knowledge of the sources you’re citing. Only use an indirect citation if you can’t reasonably gain access to the original source.

In Harvard style referencing , to distinguish between two sources by the same author that were published in the same year, you add a different letter after the year for each source:

• (Smith, 2019a)
• (Smith, 2019b)

Add ‘a’ to the first one you cite, ‘b’ to the second, and so on. Do the same in your bibliography or reference list .

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Harvard Style

The Harvard referencing system is known as the Author-Date style . It emphasizes the name of the creator of a piece of information and the date of publication, with the list of references in alphabetical order at the end of your paper.

Unlike other citation styles, there is no single, definitive version of Harvard Style. Therefore, you may see a variation in features such as punctuation, capitalization, abbreviations, and the use of italics. 

Always check with your instructor and follow the rules he or she gives you.

• Harvard Style Guidelines Your class handout
• Harvard Referencing Quick Guide From Staffordshire University

Harvard Style will affect your paper in two places:

• In-text citations in the body of your paper, and
• The reference list at the end of your paper
• All in-text citations should be listed in the reference list at the end of your paper.
• Reference list entries need to contain all the information that someone reading your paper would need in order to find your source.
• Reference lists in Harvard Style are arranged alphabetically by first author.
• Begin your Reference list on a new page after your text and number it consecutively.

Sample References List:

Click on the Links Below to See Additional Examples:

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Click on the image below to launch this tutorial that was created by the University of Leeds. The section on Citing in Text is especially useful.

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Last Updated: April 21, 2024 Fact Checked

This article was co-authored by Christopher Taylor, PhD . Christopher Taylor is an Adjunct Assistant Professor of English at Austin Community College in Texas. He received his PhD in English Literature and Medieval Studies from the University of Texas at Austin in 2014. This article has been fact-checked, ensuring the accuracy of any cited facts and confirming the authority of its sources. This article has been viewed 75,860 times.

The Harvard referencing style is used at the university level for academic essays and papers. It’s used for referencing all sorts of materials, not just websites. However, referencing a website with this style can be tricky, especially if you have not referenced a website before in a paper or essay. In just a few steps, you can create an in-text citation using Harvard referencing style or cite the website in the reference list at the end of your paper, similar to a bibliography.

Creating an In-Text Citation

• For example, you may use the title “Tourism Canada” or “The Writer’s Pen” in the citation.

• For example, you may see a note at the bottom of the website that says “Created on: January 2001” or “Revised: 2012.”
• If you cannot find the year, you can use “n.d.” in the citation to indicate no date can be found for the website.

• For example, you may write, “(Tourism Canada 2001)” or “(The Writer’s Pen 2011).”
• If there is no date on the website, you may write, “(Tourism Canada n.d.)”

• For example, if the text is quoted, you may write: “The national average for home pregnancies has doubled in the last year.” (Tourism Canada 2011)
• If the text is paraphrased, you may write: Winners of this award will receive $1,660. (The Writer’s Pen 2011)

Citing the Website in the Reference List

• For example, you may cite “Parks Ontario” or “The Canadian Cancer Society” as the title.

• For example, you may see a note at the bottom of the website that says “Created on: March 2001” or “Revised: 2017.”
• You may then write in the citation, “Parks Ontario 2001” or “The Canadian Cancer Society 2017”
• Use “n.d.” in the citation if you can’t find the creation or revision date. “N.d.” will indicate that no date can be found on the website. For example, you may write, “Parks Ontario n.d.” or “The Canadian Cancer Society n.d.”

• For example, you would use the citation, “ The Canadian Cancer Society official website ” or “ Parks Ontario corporate website .”

• For example, you may write, “viewed 21 June 2016” or “viewed 1 March 2011.”
• Here’s an example reference: The Canadian Cancer Society n.d. The Canadian Cancer Society official website , viewed 1 March 2011

• For example, you may write, “< https://www.cancer.ca/en/get-involved/take-action/what-we-are-doing/ >.”
• An example of the complete citation is: The Canadian Cancer Society n.d. The Canadian Cancer Society official website , 1 March 2011 < https://www.cancer.ca/en/get-involved/take-action/what-we-are-doing/ >.

• For example, the completed Harvard reference will look like: Parks Ontario 2011, Parks Ontario corporate website , viewed 21 June 2016, < https://www.ontarioparks.com/ >.

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About this article

To Harvard reference a website in text, put the title of the website and the year it was created in parentheses at the end of the quoted or paraphrased text. If there's no date, write "n.d." instead. For example, you would write something like "(Tourism Canada 2001)" or "(Tourism Canada n.d.)." For more tips from our English co-author, like how to cite a website in your reference list, scroll down! Did this summary help you? Yes No

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Citation guides

All you need to know about citations

How to cite a website in Harvard

To cite a website in a reference entry in Harvard style include the following elements:

• Author(s) of the website: Give the last name and initials (e. g. Watson, J.) of up to three authors with the last name preceded by 'and'. For four authors or more include the first name followed by et al., unless your institution requires referencing of all named authors.
• Year of publication: Give the year in round brackets.
• Title of the website: Give the title as presented in the source. Only the first letter of the first word and proper nouns are capitalized.
• URL: Give the full URL of the web page including the protocol (http:// or https://).
• Date of access: Give the day month and year.

Here is the basic format for a reference list entry of a website in Harvard style:

Author(s) of the website ( Year of publication ) Title of the website . Available at: URL (Accessed: Date of access ).

Take a look at our reference list examples that demonstrate the Harvard style guidelines in action:

A website by one author

Mitzewich, J . ( 2007 ) Food Wishes . Available at: https://foodwishes.blogspot.com/ (Accessed: 3 December 2016 ).

A popular website without a specific author

HelloGiggles: A Positive Community for Women ( 2011 ) Available at: https://hellogiggles.com (Accessed: 15 June 2016 ).

This citation style guide is based on the Cite Them Right (10 th edition) Harvard referencing guide.

More useful guides

• Harvard Referencing: Internet/websites
• Harvard Referencing Style
• Harvard Referencing Style Guide: All examples

More great BibGuru guides

• APA: how to cite an annual report
• Chicago: how to cite a podcast
• Harvard: how to cite an eBook

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Home / Guides / Citation Guides / Harvard Referencing / Harvard Referencing Style Examples / How to reference an article in Harvard referencing style

How to reference an article in Harvard referencing style

What is an article.

Almost all writers and academics reference other people’s writing in their works. Referencing demonstrates that you have researched your topic, are well versed in its arguments and theories, and it also helps avoid charges of plagiarism.  

The Harvard citation system is just one of many referencing styles – and which style you choose is normally guided by the institution or publication you are writing for.

In this article, you will learn how to use the Harvard citation system to reference the following types of articles:

• journal article
• newspaper article
• magazine article

Properly citing article details in the reference list will help the readers to locate your source material if they wish to read more about a particular area or topic.

Information you need:

• Author name
• (Year published)  
• ‘Article title’  
• Journal/newspaper/magazine name  
• Day and month published, if available
• Volume number, if available
• (Issue) number, if available
• Page number(s), if available

If accessed online:

• Available at: URL or DOI  
• (Accessed: date).

Journal articles

Academic or scholarly journals are periodical publications about a specific discipline. No matter what your field is, if you are writing an academic paper, you will inevitably have to cite a journal article in your research. Journal articles often have multiple authors, so make sure you know when to use et al. in Harvard style . The method for referencing a journal article in the reference list is as follows:

Reference list (print) structure:

Last name, F. (Year published) ‘Article title’, Journal name , Volume(Issue), Page(s).

Shepherd, V. (2020) ‘An exploration around peer support for secondary pupils in Scotland with experience of self-harm’, Educational Psychology in Practice, 36(3), pp. 297-312.

Note that the article title uses sentence case. However, the title of the journal uses title case. Additionally, the volume number comes immediately after the journal title followed by the issue number in round brackets.

If the original material you are referencing was accessed online, then the method for citing it in the reference list will be the same as that in print, but with an additional line at the end.  

Reference list (online) structure:

Last name, F. (Year published) ‘Article title’, Journal Name , Volume(Issue), Page(s). Available at: URL or DOI (Accessed: date).  

Shepherd, V. (2020) ‘An exploration around peer support for secondary pupils in Scotland with experience of self-harm’, Educational Psychology in Practice, 36(3), pp. 297-312. Available at: https://www.tandfonline.com/doi/full/10.1080/02667363.2020.1772726 (Accessed: 08 October 2020).

In-text citation (print or online) structure:

In-text citations are written within round brackets and start with the last name of the author followed by the year published, both separated by a comma.

You can also mention the author within the text and only include the publication year in round brackets.

Examples:  

In this article (Shepherd, 2020) deals with…  

According to Shepherd (2020), when peer support is available…  

Talking about the secondary education system, Shepherd (2020, p.299) suggests that…

Newspaper articles

Even if you are referring to an incident which is public knowledge, you still need to cite the source.  

The name of the author in a newspaper article is referred to as a byline. Below are examples for citing an article both with and without a byline.  

Reference list (print) structure:  

Last name, F. (Year published). ‘Article title’, Newspaper name , Day Month, Page(s).

Hamilton, J. (2018). ‘Massive fire at local department store’, The Daily Local, 10 August, p. 1.

Last name, F. (Year published). ‘Article title’, Newspaper name , Day Month, Page(s). Available at: URL (Accessed: Day Month Year).

Gambino, L. (2020) ‘Kamala Harris and Mike Pence clash over coronavirus response in vice-presidential debate,’ The Guardian, 8 October. Available at: https://www.theguardian.com/us-news/2020/oct/07/debate-kamala-harris-mike-pence-latest-news (Accessed: 8 October 2020).

Reference list structure, no byline:

The basic reference list structure for the reference is the same for both print and online articles. If information isn’t available, simply omit it from the reference.

Newspaper name (Year published) ‘Article Title’, Day Month, Page(s). Available at: URL (Accessed: Day Month Year).

The Chronicler (2016) ‘Local man wins lottery jackpot twice in one year’, 30 May, p. 14. Available at: https://thechroniclerpaper.com/local-man-wins-lottery-twice (Accessed: 1 October 2020).

In-text citation structure (print or online):

The last name of the author and date are written in round brackets, separated by a comma. The method is similar to referencing journal articles in in-text citations.

(Hamilton, 2018)

In his paper, Gambino (2020) mentioned that…

For articles accessed online which do not have an author, the name of the publication is mentioned in place of the author’s name and is italicized.

( The Chronicler , 2016)

Magazine articles  

The structure of magazine articles is similar to that of a journal article.

Last name, F. (Year published) ‘Article title’, Magazine Name , Volume(Issue), Page(s).

Ornes, S. (2020). “To save Appalachia’s endangered mussels, scientists hatched a bold plan”, ScienceNews, (198), p.2.

Last name, F. (Year published) ‘Article title’, Magazine name , Volume(Issue), Page(s). Available at: URL (Accessed: Date).

Ornes, S. (2020) ‘To save Appalachia’s endangered mussels, scientists hatched a bold plan’, ScienceNews, (198), p.2. Available at: https://www.sciencenews.org/article/endangered-mussels-appalachia-rivers-biologists-conservation-plan (Accessed: 3 October 2020).

  In-text citation (print or online) structure:

(Author last name, Year published)

(Ornes, 2020)

Published October 29, 2020.

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• When neither the author nor the page number is mentioned in the body of the sentence, you should include both the author’s last name and the page number in the parenthetical citation.

Colleges and universities need to create policies that foster inclusion for low-income students (Jack 24).

• When the author’s name is mentioned in the sentence, you should include only the page number in your parenthetical citation.

As Anthony Jack argues, colleges and universities need to create policies that foster inclusion for low-income students (24).

• If the source you are writing about does not have page numbers, or if you consulted an e-book version of the source, you should include only the author’s name in the parenthetical citation:

Colleges and universities need to create policies that foster inclusion for low-income students (Jack).

• If you mention the author in the body of the sentence and there is no page number in the source, you should not include a parenthetical citation.

As Anthony Jack argues, colleges and universities need to create policies that foster inclusion for low-income students.

• If you are referring to an entire work rather than a specific page, you do not need to include a page number.

In The Privileged Poor, Anthony Jack describes many obstacles that low-income students face at selective colleges and universities.

• If you are referring to a source that has no listed author, you should include the title (or a shortened version of the title) in your parenthetical citation.

Harvard College promises “to educate the citizens and citizen-leaders for our society” (“Mission, Vision, & History”).

• If you are referring to a source that has two authors, you should include both authors in your parenthetical citation.

The researchers tested whether an intervention during the first year of college could improve student well-being (Walton and Cohen 1448).

• If you refer to a source that has more than two authors, you should include the first author’s name followed by et al. ( Et al. is an abbreviation for et alia which means “and others” in Latin.) When you use et al. in a citation, you should not put it in italics.

The researchers studied more than 12,000 students who were interested in STEM fields (LaCosse et al. 8).

• If you refer to more than one source by the same author in your paper, you should include the title (or a shortened version of the title) in your parenthetical citation so that readers will know which source to look for in your Works Cited list. If you mention the author’s name in the sentence, you only need to include the title and page number. If you mention the author and title in the sentence, you only need to include the page number.

Colleges and universities need to create policies that foster inclusion for low-income students (Jack, Privileged Poor 24).

According to Anthony Jack, colleges and universities need to create policies that foster inclusion for low-income students ( Privileged Poor 24).

As Anthony Jack writes in Privileged Poor, colleges and universities need to create policies that foster inclusion for low-income students (24).

• If you want to credit multiple authors for making the same point, you can include them all in one parenthetical citation. 

Students who possess cultural capital, measured by proxies like involvement in literature, art, and classical music, tend to perform better in school (Bourdieu and Passeron; Dumais; Orr).

• If you refer to a source that includes line numbers in the margins, numbered paragraphs, numbered chapters, or numbered sections rather than page numbers, you should include the number in your parenthetical citation, along with “line,” “ch./ chs.,” or “sec./secs.”   You can include stable numbering like chapters even when there are no stable page numbers (as in an e-book). You should separate “line” or other designation from the work’s title or author’s name with a comma.  If the source does not include this type of numbering, you should not include it either.

We learn that when he went to the store to buy clothes for his son, “a frantic inspection of the boys’ department revealed no suits to fit the new-born Button” (Fitzgerald, ch.2).

• If you are citing a play, you should include the act and scene along with line numbers (for verse) or page numbers, followed by act and scene, (for prose).

Guildenstern tells Hamlet that “there has been much throwing about of brains” (Shakespeare, 2.2. 381-382).

Chris is in this mindset when he says, “a couple minutes, and your whole life changes, that’s it. It’s gone” (Nottage, 13; act 1, scene1).

• If you are referring to a video or audio recording that contains time stamps, you should include the time in your parenthetical citation to make it easy for your readers to find the part of the recording that you are citing.

In the Stranger Things official trailer, the audience knows that something unusual is going to happen from the moment the boys get on their bicycles to ride off into the night (0:16).

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How to Cite a Website in Harvard Style?

Published by Alaxendra Bets at August 27th, 2021 , Revised On August 23, 2023

Citing a website depends on whether one needs to cite an entire website, a webpage of a website, a blog post, an entire blog, or something in between these. Harvard style has slightly varying formats for citing and referencing such sources. They are further discussed below.

But first, let’s look at some key terms and what they mean:

• Website: is the general, broader thing that contains a lot of other pages within it.
• Webpage: is the page on a website; different web pages combine to give one website.
• Blog: is like a website, but the difference lies in the frequency content is uploaded or modified; it’s done more regularly for a blog than for a website.
• Blog post: is a post that combines with other posts to create an entire blog; much like webpages combine to form an entire website.

The citation and reference formats for all these web sources only differ slightly in Harvard style.

Types of Web Sources, how they’re Referenced, and Examples

Following are the major types of web sources and how they are cited and referenced, along with some examples.

1.    Citing a basic webpage/website

In-text citation: (Author surname or authoring body name Year the webpage was last updated or revised)

Reference list entry: Author surname, Initial(s) Year (page created or revised), Title of the webpage/website in italics, Publisher (if applicable), viewed Day Month Year, <URL>.

For example:

In-text citation: (Beard 2006)

Reference list entry: Beard, M 2006, The fall of the Roman Republic , viewed 30 January 2011, <http://www.bbc.co.uk/history/ancient/romans/

fallofromanrepublic_article_01.shtml>.

Some important things to note while citing webpages

• If a webpage/website has a lengthy URL or one that is difficult to cite, it can be broken up by inserting slash marks in between keywords. OR
• The name of the main website can be given instead of the webpage.

However, before deciding on either of the two, it should first be confirmed by what one’s host institution specifies in its referencing guidelines. And whichever method is used in the end should be used consistently throughout the manuscript.

2.    Citing a webpage/website with organisation as author

The format remains the same as that of a webpage/website/ with an author, except that in place of the author’s surname, the authoring organisation name is used instead.

In-text citation: (Organisational name Year the webpage/website was last updated or revised) OR

(Organisational name Year the webpage was last updated or revised, p.# for a single page or pp.# for page range)

Reference list entry: Organisational name Year (page created or revised), Title of the specific webpage/website in italics, Publisher (if applicable), viewed Day Month Year, <URL>.

In-text citation: (Attorney-General’s Department 1998) OR

(Attorney-General’s Department 1998, p. 10)

Reference list entry: Attorney-General’s Department 1998, Review of the Commonwealth’s ‘Acts Interpretation Act 1901’ , viewed 1 October 1999, <http://www.law.gov.au>.

3.    Citing a report, PDF, or another form of documents from a webpage

Sometimes, certain web pages turn out to be PDF documents that must be downloaded first. It can also be a report, again, one has that to be downloaded first to be viewed. In such a case, the webpage is cited and referenced as follows:

In-text citation: (Author surname Year the webpage document was last updated or revised)

Reference list entry: Author surname, Initial/s Year, Title of the specific webpage document in italics, Publisher if applicable, viewed Day Month Year, <URL of specific document>.

In-text citation: (D’Amato, Henderson & Florence 2009) OR

(D’Amato, Henderson & Florence 2009, p. 32)

Reference list entry: D’Amato, A, Henderson, S & Florence, S 2009, Corporate social responsibility and sustainable business: a guide to leadership tasks and functions , Centre for Creative Leadership, viewed 22 January 2015, <http://insights.ccl.org/wp-content/uploads/2015/04/CorporateSocialResponsibility.pdf>.

The above example is of citing a PDF webpage. Here’s one of a webpage report in the same format:

In-text citation: (Gabriel et al. 2010) OR

(Gabriel et al. 2013, p. 24)

Reference list entry: Gabriel, M, Watson, P, Ong, R, Wood, G & Wulff, M 2010, The environmental sustainability of Australia’s private rental housing stock , AHURI Position Paper no. 125, Australian Housing and Urban Research Institute, viewed 25 May 2015, <https://www.ahuri.edu.au/__data/assets/pdf_file/0023/2894/

AHURI_Positioning_Paper_No125_The-environmental-sustainability-of-Australias-private-rental-housing-stock.pdf>.

4.    Citing a webpage/website with a DOI

A DOI stands for digital object identifier. It’s a form of ‘name tag’ for a document on the web. DOIs are mostly for journal articles, so that finding them from a journal database, for instance, becomes easy. However, DOIs are also assigned to government reports, PDFs and other similar document types.

In Harvard style, a government or company websites/webpages with a DOI may be cited and referenced as follows:

In-text citation: (Author surname Year the DOI webpage/website document was last updated or revised)

Reference list entry: Author surname, Initial/s Year, Title of a specific document, Publisher if applicable, doi.

In-text citation: (International Energy Agency 2020) OR

(International Energy Agency 2020, p. 32)

Reference list entry: International Energy Agency (IEA) 2020, Luxembourg 2020: energy policy review , OECD Publishing, Paris, https://doi.org/10.1787/54355dd7-en.

5.    Citing a website/webpage with no author

To cite such a web source, the reference begins with the title of the webpage or the webpage document, rather than the author’s surname. The format is:

In-text citation: (Title of webpage or webpage document in italics Year the webpage/document was last updated or revised)

Reference list entry: Title of webpage or webpage document in italics Year, Publisher (if applicable), viewed Day Month Year, <URL>.

In-text citation: ( More sugar 2020)

Reference list entry: More sugar, more problems 2020, viewed 31 January 2020,

<https://www.nm.org/healthbeat/healthy-tips/nutrition/more-sugar-more-problems>.

Similarly, in the case of an entire website, its title is written in place of the webpage in the above format.

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6.    Citing a webpage/website with no publication date or year

The abbreviations n.d. are simply written in place of publication year or date. They stand for ‘no date.’ The format then is:

In-text citation: (Author n.d.)

Reference list entry: Author n.d., Title of the specific document in italics, viewed Day Month Year, <URL of specific document>.

In-text citation: (Royal Institute of British Architects n.d.)

Reference list entry: Royal Institute of British Architects n.d., Shaping the future: careers in architecture , viewed 31 May 2005, <http://ww.careersinarchitecture.net>.

Reference list entry:

7.    Citing an entire blog

In-text citation: (Author surname Year the blog was last modified or revised)

Reference list entry: Author surname, Initial(s) Year, Title of the blog in italics, format i.e. blog, viewed Day Month Year, <URL>.

In-text citation: (Strong 2016)

Reference list entry: Strong, F 2016, Sword and the script, blog, viewed 23 July 2016,

<http://www.swordandthescript.com/>.

8.    Citing a single blog post published on a blog

In-text citation: (Author surname Year the blog post was last modified or revised)

Reference list entry: Author surname, Initial(s) Year, ‘Title of specific post’, Blog title in italics, blog post, viewed Day Month Year, <URL>.

Note: For such a source, Harvard referencing italicises the title of the blog, whereas the title of the specific blog post is written within single quotes.

In-text citation: (Hagon 2009)

Reference list entry: Hagon, P. 2009, ‘Immediate sharing’, What’s New , blog post, viewed 10 January 2009, <http://www.paulhagon.com/ blog/2009/09/27/immediate-sharing/>.

Citing other Kinds of Web Sources

Apart from a webpage, website, blog or blog post, there are also Wiki pages, Facebook posts and Facebook pages. Harvard referencing has unique formats to cite and reference such sources. They are discussed below, along with a few examples.

9.    Citing a Wiki web source

The Harvard style to cite and reference a Wiki webpage WTH author name is:

In-text citation: (Author surname OR short title Year the Wiki page was last revised or edited) OR

(Author surname OR short title Year, p.# or para. # [if known])

Reference list entry: Author surname, Initial(s) Year, ‘Title of post’, Title of Wiki in italics, viewed Day Month Year, <URL>. OR

In-text citation: (Roussel 2008)

Reference list entry: Roussel, S 2008, Sustainability indicators, Coastal Wiki , viewed 25 May 2013, <http://www.coastalwiki.org/wiki/Sustainability_indicators>.

And the reference format for a Wiki page WITHOUT an author name in Harvard style is: ‘Title of post’ Year, Title of Wiki in italics, viewed Day, Month, Year, <URL>.

In-text citation: (Cultural issues 2007) OR

(Cultural issues 2007, para. 2) OR

Reference list entry: ‘Cultural issues affecting international trade’ 2007, Wikiversity , viewed 27 October 2009, <http://en.wikiversity.org/wiki/ Cultural_Issues_Affecting_International_Trade>.

10.  Citing a Facebook post

According to Harvard style, posts from a Facebook page or group are cited as follows:

In-text citation: (Author name Year)

Reference list entry: Author surname, Initial(s) Year, ‘The first few words of the post, […]’, Facebook post, Day Month, viewed Day Month Year, <URL>.

In-text citation: (World Bank 2016)

Reference list entry: World Bank 2016, ‘How would you convince business owners to pay taxes? […]’, facebook post, 18 June, viewed 28 June 2016, <https://www.facebook.com/worldbank/?fref=nf>.

11.  Citing a Facebook webpage

Facebook pages—also in the form of webpages, essentially—are pages showcasing the profile owner’s information. In case of companies or other groups, Facebook pages serve their official product pages, too.

In Harvard style, such sources are cited and referenced as follows:

In-text citation: (Author name n.d.)

Reference list entry: Author name, Initial(s) n.d., Title of the Facebook page in italics, format i.e., Facebook page, viewed Day Month Year, <URL>.

Note: Just like a website, a Facebook page will not have a publication date. No date or ‘n.d.’ is written instead of date and year of publication.

In-text citation: (Smith n.d.)

Reference list entry: Smith, J n.d., Timeline , facebook page, viewed 17 August 2018, <https://www.facebook.com/john.smith12/>.

Another thing to keep in mind while referencing a Facebook page is that since Facebook doesn’t really have pages per say, but rather sections on a single webpage, the section titles are used as page titles.

For instance, page sections called ‘Timeline,’ ‘About,’ ‘Contact’ etc. are used in the reference list entry in place of page title.

Frequently Asked Questions

How do you cite a website harvard.

To cite a website in Harvard style:

• Author(s) Last Name, First Initial. (Year).
• Title of webpage. [Online].
• Website Name. Available at: URL (Accessed: Date). Add a specific page or publication date if available. Include the retrieved date if the content might change.

You May Also Like

In Harvard referencing style, the basics of in-text citation for personal communications.

To cite a tweet or Twitter page, simply include the URL of the page in the text in round brackets. The details are discussed in this guide

Author Surname, Author Initial. (Year Published). Title. In: Publication Title. [online] City: Publisher, p.Pages Used. URL [Accessed Date Accessed].

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• How It Works

• Aberystwyth University
• Referencing & Plagiarism Awareness
• 3. How to insert citations into your assignment.

Referencing & Plagiarism Awareness: 3. How to insert citations into your assignment.

• 1. Introduction
• 2. What is referencing and citation?
• 4. What is plagiarism?
• 5. Referencing Artificial Intelligence Outputs
• 6. Consequences of plagiarism
• 7. Plagiarism in the news
• 8. Referencing Examples
• 9. Reference management tools
• 10. Submitting your work using Turnitin
• 11. How to interpret your Turnitin similarity report
• 12. Further help

What is citing?

Citing is identifying the sources you have used in the text of your assignment.  This may be done as;

a direct quotation

paraphrasing

summarising

In-text citations give brief details about the source that you refer to.

This is an example citation (Harvard referencing style):

(Pears and Shields, 2013)  

Further citation examples from the different referencing styles used at Aberystwyth University can be found here .

The citations will allow the person reading your assignment to locate the full details of the source you have used in the reference list located at the end of your work.

Reference list (Harvard Style)

Pears, R. and Shields, G. (2013) Cite them right: the essential referencing guide . London: Palgrave.

Pears, R. and Shields, G. (2013). Cite them right: the essential referencing guide . London: Palgrave.

How to use quotes in your assignment.

When you use quotations they should be relevant.  Try not to use too many as they can break the flow of your text.  You will need to balance quotations with your own understanding of the sources used.

Don't forget - quotes are included in your word count!

A few tips:

Enclose any quotes in " quotation marks " - be consistent. Check out the further examples to see whether your chosen referencing style uses single or double quotation marks.

If using long quotes that are more than a few sentences, add these as a separate paragraph. This should be indented and there is no need to use quotation marks. ( Please note : The Department of Geography and Earth Sciences stipulate that long, indented quotations require quotation mark at the beginning and the end of the quotation).

Depending on the referencing style you are using, give the author, date and page number that the quote is from.

The full details of the source of the quote are then added into the reference list at the end of your assignment.

Example (Harvard Style):

In-text citation

'There are several ways in which you can incorporate citations into your text, depending on your own style and the flow of the work' (Pears and Shields, 2013, p. 8).

Reference list

How to paraphrase.

Paraphrasing involves expressing another author’s ideas or arguments in your own words, without direct quotation but with due acknowledgement.  It entails reformulating key points or information accurately, so that nothing important is lost but the means of communication is new. For instance:

Quotation     ‘It is impossible to step twice into the same river’ (Heraclitus) Paraphrase     Heraclitus argues that, just as a river is always in motion, the world is always changing so that nothing stays the same.

Paraphrasing can help with the flow or continuity of your written work and is a good way of demonstrating your understanding.

Read your source a few times to ensure you understand the meaning

Restate the key point(s) from the source in your own words, but without distorting the original meaning

Ensure you cite and reference the source.

Please note: When paraphrasing, you should NOT copy a passage from your source and then seek to change some of its wording. Use your own words and phrases from beginning to end when paraphrasing.

How to summarise.

This method provides the key points from an article, book or web page as a brief statement.

A few Tips;

Summaries should be your own work. It is NOT permitted to use online summary tools or other software for this purpose.

Ensure you cite and reference the source

Only list the main topics

In text citation

Importantly, one particular book (Pears and Shields, 2013) looks at the different citation methods when including them in an assignment.

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• Introduction
• Parenthetical vs. narrative
• Multiple authors

Missing information

• Sources to include

Tools and resources

• Scroll to top

How to create APA citations

APA Style is widely used by students, researchers, and professionals in the social and behavioral sciences. Scribbr’s free citation generator automatically generates accurate references and in-text citations.

This citation guide outlines the most important citation guidelines from the 7th edition APA Publication Manual (2020).

• Cite a webpage
• Cite a book
• Cite a journal article
• Cite a YouTube video

APA in-text citations

APA in-text citations include the author’s last name, publication date, and, if relevant, a locator such as a page number or timestamp. For example, (Smith, 2021, p. 170) . See it as a shorter version of the entry in the reference list .

You should include in-text citations every time you’re quoting or paraphrasing someone else’s ideas or words. In doing so, you give credit to the original author and avoid plagiarism .

Parenthetical vs. narrative citation

The in-text citation can take two forms: parenthetical and narrative. Both types are generated automatically when citing a source with Scribbr’s APA Citation Generator.

• Parenthetical citation: According to new research … (Smith, 2020) .
• Narrative citation: Smith (2020) notes that …

Multiple authors and corporate authors

The in-text citation changes slightly when a source has multiple authors or an organization as an author. Pay attention to punctuation and the use of the ampersand (&) symbol.

When the author, publication date or locator is unknown, take the steps outlined below.

APA Citation Generator

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APA references

APA references generally include information about the author , publication date , title , and source . Depending on the type of source, you may have to include extra information that helps your reader locate the source.

It is not uncommon for certain information to be unknown or missing, especially with sources found online. In these cases, the reference is slightly adjusted.

Formatting the APA reference page

On the first line of the page, write the section label “References” (in bold and centered). On the second line, start listing your references in alphabetical order .

Apply these formatting guidelines to the APA reference page:

• Double spacing (within and between references)
• Hanging indent of ½ inch
• Legible font (e.g. Times New Roman 12 or Arial 11)
• Page number in the top right header

Which sources to include

On the reference page, you only include sources that you have cited in the text (with an in-text citation ). You should not include references to personal communications that your reader can’t access (e.g. emails, phone conversations or private online material).

In addition to the APA Citation Generator, Scribbr provides many more tools and resources that help millions of students and academics every month.

• Citation Generator : Generate flawless citations in APA, MLA , and Harvard style .
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• Summarizer: Read more in less time. Distill lengthy and complex texts down to their key points.
• AI detector: Find out if your text was written with ChatGPT or any other AI writing tool. ChatGPT 2 & ChatGPT 3 supported.
• Proofreading services : Have a professional editor (or team of editors) improve your writing so you can submit your paper with pride and confidence. Scribbr offers admission essay editing , paper editing , and academic editing .
• Guides and videos : Explore hundreds of articles, bite-sized videos, time-saving templates, and handy checklists that guide you through the process of research, writing, and citation.

Webpage on a Website References

This page contains reference examples for webpages, including the following:

• Webpage on a news website
• Comment on a webpage on a news website
• Webpage on a website with a government agency group author
• Webpage on a website with an organizational group author
• Webpage on a website with an individual author
• Webpage on a website with a retrieval date

1. Webpage on a news website

Bologna, C. (2019, October 31). Why some people with anxiety love watching horror movies . HuffPost. https://www.huffpost.com/entry/anxiety-love-watching-horror-movies_l_5d277587e4b02a5a5d57b59e

Roberts, N. (2020, June 10). Trayvon Martin’s mother, Sybrina Fulton, qualifies to run for elected office . BET News. https://www.bet.com/news/national/2020/06/10/trayvon-martin-mother-sybrina-fulton-qualifies-for-office-florid.html

Toner, K. (2020, September 24). When Covid-19 hit, he turned his newspaper route into a lifeline for senior citizens . CNN. https://www.cnn.com/2020/06/04/us/coronavirus-newspaper-deliveryman-groceries-senior-citizens-cnnheroes-trnd/index.html

• Parenthetical citations : (Bologna, 2019; Roberts, 2020; Toner, 2020)
• Narrative citations : Bologna (2019), Roberts (2020), and Toner (2020)
• Use this format for articles from news websites. Common examples are BBC News, BET News, Bloomberg, CNN, HuffPost, MSNBC, Reuters, Salon, and Vox. These sites do not have associated daily or weekly newspapers.
• Use the newspaper article category for articles from newspaper websites such as The New York Times or The Washington Post .
• Provide the writer as the author.
• Provide the specific date the story was published.
• Provide the title of the news story in italic sentence case.
• List the name of the news website in the source element of the reference.
• End the reference with the URL.

2. Comment on a webpage on a news website

Owens, L. (2020, October 7). I propose a bicycle race between Biden and Trump [Comment on the webpage Here’s what voters make of President Trump’s COVID-19 diagnosis ]. HuffPost. https://www.spot.im/s/00QeiyApEIFa

• Parenthetical citation : (Owens, 2020)
• Narrative citation : Owens (2020)
• Credit the person who left the comment as the author using the format that appears with the comment (i.e., a real name and/or a username). The example shows a real name.
• Provide the specific date the comment was published.
• Provide the comment title or up to the first 20 words of the comment in standard font. Then in square brackets write “Comment on the webpage” and the title of the webpage on which the comment appeared in sentence case and italics.
• Provide the name of the news website in the source element of the reference.
• Link to the comment itself if possible. Otherwise, link to the webpage on which the comment appears. Either a full URL or a short URL is acceptable.

3. Webpage on a website with a government agency group author

National Institute of Mental Health. (2018, July). Anxiety disorders . U.S. Department of Health and Human Services, National Institutes of Health. https://www.nimh.nih.gov/health/topics/anxiety-disorders/index.shtml

• Parenthetical citation : (National Institute of Mental Health, 2018)
• Narrative citation : National Institute of Mental Health (2018)
• For a page on a government website without individual authors, use the specific agency responsible for the webpage as the author.
• The names of parent agencies not present in the author element appear in the source element (in the example, U.S. Department of Health and Human Services, National Institutes of Health). This creates concise in-text citations and complete reference list entries.
• Provide as specific a date as possible for the webpage.
• Some online works note when the work was last updated. If this date is clearly attributable to the specific content you are citing rather than the overall website, use the updated date in the reference.
• Do not include a date of last review in a reference because content that has been reviewed has not necessarily been changed. If a date of last review is noted on a work, ignore it for the purposes of the reference.
• Italicize the title of the webpage.

4. Webpage on a website with an organizational group author

World Health Organization. (2018, May 24) . The top 10 causes of death . https://www.who.int/news-room/fact-sheets/detail/the-top-10-causes-of-death

• Parenthetical citation : (World Health Organization, 2018)
• Narrative citation : World Health Organization (2018)
• For a page from an organization’s website without individual authors, use the name of the organization as the author.
• Because the author of the webpage and the site name are the same, omit the site name from the source element to avoid repetition.

5. Webpage on a website with an individual author

Horovitz, B. (2021, October 19). Are you ready to move your aging parent into your home? AARP. https://www.aarp.org/caregiving/home-care/info-2021/caregiving-questions.html

Schaeffer, K. (2021, October 1). What we know about online learning and the homework gap amid the pandemic. Pew Research Center. https://www.pewresearch.org/fact-tank/2021/10/01/what-we-know-about-online-learning-and-the-homework-gap-amid-the-pandemic/

• Parenthetical citations : (Horovitz, 2021; Schaeffer, 2021)
• Narrative citations : Horovitz (2021) and Schaeffer (2021)
• When individual author(s) are credited on the webpage, list them as the author in the reference.
• Provide the site name in the source element of the reference.

6. Webpage on a website with a retrieval date

U.S. Census Bureau. (n.d.). U.S. and world population clock . U.S. Department of Commerce. Retrieved January 9, 2020, from https://www.census.gov/popclock/

• Parenthetical citation : (U.S. Census Bureau, n.d.)
• Narrative citation : U.S. Census Bureau (n.d.)
• When contents of a page are designed to change over time but are not archived, include a retrieval date in the reference.

Webpage references are covered in the seventh edition APA Style manuals in the Publication Manual Section 10.16 and the Concise Guide Section 10.14

What We Did and Did Not Argue in United States v. Trump – Seth Barrett Tillman & Josh Blackman

Posted by JLPP on Jul 16, 2024 in Per Curiam

What We Did and Did Not Argue in United States v. Trump

Seth barrett tillman *, josh blackman **.

Editor’s Note : This essay had already been submitted to the Harvard Journal of Law & Public Policy before United States v. Trump was decided by the United States District Court for the Southern District of Florida on July 15, 2024. The authors have decided to publish this essay without regard to the District Court’s decision, and they will address that decision in future writings.

On June 21, 2024, Judge Aileen Cannon of the United States District Court for the Southern District of Florida heard oral argument in United States v. Trump . This prosecution was brought by Special Counsel Jack Smith with regard to former President Trump’s possession of certain documents at Mar-A-Lago. Blackman presented oral argument that day based on an amicus brief we had filed, with the Landmark Legal Foundation, in March.

Our goal here is to explain the lines of argument we put forward in our amicus brief , our motion , and at the hearing on Friday, June 21, 2024. [1] We will address three questions. First, does United States v. Nixon require the District Court to dismiss the former President’s motion to dismiss the indictment? Second, does the Special Counsel hold a continuous “Officer of the United States” position? And third, has Congress appropriated money to pay the Special Counsel and his staff and contractors?

I. Does Nixon Require the District Court to Dismiss Former President’s Motion to Dismiss the Indictment?

There are two primary legal questions raised by Trump’s motion to dismiss the indictment. First, is the Special Counsel’s office or position constitutional? [2] And second, was Smith lawfully appointed to hold that position?

Not surprisingly, the Special Counsel answered both questions in the affirmative. The Special Counsel’s position squarely relied upon United States v. Nixon (1974). [3] In Nixon , Special Prosecutor Jaworski sought to enforce a subpoena against President Nixon, and the Supreme Court, with certain limitations, upheld the lawfulness of the subpoena. Even if not expressly stated, the Court’s opinion implied, to some extent, that the position of special prosecutor was constitutional. In the Trump litigation in the Southern District of Florida, Special Counsel Smith analogized the position he (purportedly) holds to that held by Special Prosecutor Jaworski. To put it simply, Special Counsel Smith argued that Nixon was on-point, controlling, and remains good law—until overruled by the Supreme Court.

Trump’s counsel made three arguments in response. First, that Nixon was undermined by subsequent developments in the Supreme Court’s Appointments Clause jurisprudence. Second, that the lawfulness of the special prosecutor’s position was not argued by the parties in Nixon . And third, that the Nixon Court’s implicit determination (such as it was) that the special prosecutor’s position was lawful was, at best, dicta, and so not controlling. These arguments were also advanced by an amicus brief filed by Attorneys General Meese and Mukasey, Professors Calabresi and Lawson, and Citizens United.

During oral argument, we made a different argument. We assumed for the sake of argument that the parties in Nixon had raised the issue: that is, whether the special prosecutor’s position was lawful. We further assumed that the Court’s decision squarely addressed that issue. We even assumed that in addressing that issue, the decision on this point was the Court’s holding , and not dicta . Even with all of these assumptions in place, Nixon is not controlling in United States v. Trump . Why? A prior decision is only controlling, as opposed to persuasive, where the facts are the same. And here, the facts are not the same. [4]

We put forward three reasons in support of our position. First , the Nixon Court repeatedly described the circumstances giving rise to the conflict as unique . [5] The Court described the special prosecutor as having “unique authority and tenure. [6] And finally, the Court plainly stated that the case was decided based on “the unique facts of this case.” [7] When the Court tells the parties, the legal community, and the country that the facts are “unique” and when it does so multiple times, the implication is that other cases are, in fact, dis similar and that the holding should not be extended to different facts at a subsequent date. Nixon was the proverbial ticket good for one ride—or perhaps, one president. Bush v. Gore could be characterized in a similar fashion. [8]

Second , the Nixon Court supported its decision by expressly relying on several statutory provisions, and on regulations put into effect in 1973 by Acting Attorney General Robert Bork. [9] Although the former statutory provisions remain in effect, the latter regulations were superseded by the Ethics in Government Act (1978), which created independent counsels. The 1978 act, because it was not re-authorized by Congress, expired in 1999. Subsequently, new regulations were put into effect in 1999 by Attorney General Reno. The Nixon -Court-era regulations for special prosecutors and the modern, now-in-force Reno regulations for special counsels are not the same. For that reason alone, Nixon is not and cannot be controlling: Nixon relied upon federal regulations which are no longer in effect. [10]

Third , the Nixon Court explained why the 1973 Bork regulations were significant. The Court noted:

The Attorney General will not countermand or interfere with the Special Prosecutor’s decisions or actions. The Special Prosecutor will determine whether and to what extent he will inform or consult with the Attorney General about the conduct of his duties and responsibilities. In accordance with assurances given by the President to the Attorney General that the President will not exercise his Constitutional powers to effect the discharge of the Special Prosecutor or to limit the independence that he is hereby given, the Special Prosecutor will not be removed from his duties except for extraordinary improprieties on his part and without the President’s first consulting the Majority and the Minority Leaders and Chairmen and ranking Minority Members of the Judiciary Committees of the Senate and House of Representatives and ascertaining that their consensus is in accord with his proposed action. [11]

Under the 1973 Bork regulations, the special prosecutor enjoyed unique and a since unmatched level of independence. The special prosecutor was beyond the ordinary removal power of the President, who, in the ordinary course, can remove high ranking Executive Branch officers of the United States at pleasure. Under the Bork regulations, the special prosecutor could not be removed even for “good cause;” rather, he could only be removed for “extraordinary improprieties.” Again, this level of independence is well beyond what appears in the Reno regulations. [12] Finally, the 1973 Bork regulations permitted removal of a special prosecutor only after the President had consulted and sought consensus from eight high ranking members of Congress. Not only do modern special counsels enjoy no such protections against removal, any effort in this manner to insulate special counsels against presidential removal would seem to be plainly forbidden by more recent developments in Supreme Court case law. [13] To put it simply, the Nixon decision, to the extent it validated the office of special prosecutor as lawful, did so based on a regulatory framework that is no longer in force and which could not be put into effect today by statute due to Bowsher v. Synar . Nixon was predicated on a unique and an unmatched level of independence vested in special prosecutors. By contrast, today’s special counsel, including Jack Smith, enjoy no such independence against removal. Thus, Nixon is not controlling.

In making the argument above, we only conclude that Nixon is not controlling ; it does remain persuasive —as do other more recent Supreme Court Appointments Clause decisions.

II. Does the Special Counsel hold a continuous “Officer of the United States” position?

In United States v. Hartwell (1867), a clerk in the Treasury Department was charged with embezzlement. [14] The relevant federal statute applied to an “officer” who was “charged with the safe-keeping of the public money.” [15] The defendant argued that because he was not an “officer,” the indictment was defective. The Supreme Court disagreed and found that he was an “officer.” Justice Swayne, writing for the majority, offered the following definition of an office: “An office is a public station, or employment, conferred by the appointment of government. The term embraces the ideas of tenure, duration, emolument, and duties.” [16] To be sure, in Hartwell , the Court’s definition of “officer” involved only statutory construction. Hartwell ’s four-factor test would again play a role in United States v. Germaine (1879)—another statutory construction case construing “officer.” [17] Finally, in 1890, the Court would apply the Germaine-Hartwell four-factor framework in Aufformordt v. Hedden , where the Court construed the meaning of “officer” as used in the Constitution’s Appointments Clause. [18]

The Court returned to this issue in Buckley v. Valeo (1976), two years after Nixon . [19] Buckley did not entirely abandon the Germaine-Hartwell four-factor test, but the Court took a different approach to the “officer” issue. The Buckley Court distinguished “employees” of the United States from “officers of the United States.” The former “are lesser functionaries subordinate to officers of the United States.” [20] By contrast, in regard to Article II “officers of the United States,” the Court explained: “We think . . . any appointee exercising significant authority pursuant to the laws of the United States is an ‘Officer of the United States,’ and must , therefore, be appointed in the manner prescribed by § 2, cl. 2, of that Article.” [21] Must , not may . And more recently, in Lucia v. SEC (2018), the Court adopted Buckley ’s “significant authority” test, [22] and further held that in order for a position to be an “officer of the United States that . . . individual must occupy a ‘continuing’ position established by law.” [23] Again, must , not may . [24] The position held by Special Counsel Smith does not meet this standard.

What makes a position “continuous”? In Morrison v. Olson (1988), Chief Justice Rehnquist identified three factors:

Finally, appellant’s office is limited in tenure. There is concededly no time limit on the appointment of a particular counsel. Nonetheless, the office of independent counsel is “temporary” in the sense that an independent counsel is [1] appointed essentially to accomplish a single task, and [2] when that task is over the office is terminated, either by the counsel herself or by action of the Special Division. Unlike other prosecutors, [3] appellant has no ongoing responsibilities that extend beyond the accomplishment of the mission that she was appointed for and authorized by the Special Division to undertake. [25]

Smith does not hold a “continuing position.” [26] First, Attorney General Garland’s order appointing Smith listed a finite set of circumstances to investigate. Indeed, if Smith wanted to conduct an investigation beyond the items enumerated in the order, he would need to seek further authorization from the Attorney General.

Second, once Smith completes his investigation and prosecution of those finite set of circumstances, his position ceases to exist. By contrast, a continuing position is a position which exists independent of the current holder, and even exists if the position is vacant. As we explain in our brief, the position of Independent Counsel under the former Ethics in Government Act (1978) met this standard due to the statutory regime that created a permanent umbrella structure. That continuing position expressly provided for a successor if the current holder had been removed, died, or resigned. By contrast, Smith’s position is entirely tied to his person, and his continuing in that position. Smith’s position or “office” is entirely tied to Smith. If Smith were removed, died, or resigned, then the position he holds would cease to exist.

Third, Smith has no ongoing responsibilities after the finite set of circumstances in the appointing order are resolved. Were President Biden to issue a complete pardon to Donald Trump and his co-defendants tomorrow, Smith would have nothing to do.

At oral argument, Jack Smith’s counsel was pressed on the issue of continuity. He stated:

We think Jack Smith’s counsel has erred here by conflating a continuous position and episodic duties. In Morrison , Chief Justice Rehnquist expressly distinguished these categories. Above, we quoted a Rehnquist passage concerning the need for a position to be continuous. In the immediately preceding paragraph, Rehnquist offered a different analysis to explain why the duties must be regular, rather than episodic. In other words, as under the Germaine-Hartwell framework, the duration or continuity of an office as opposed to the regularity of the duties of the office are distinct factors or categories. As Rehnquist stated:

Second, appellant is empowered by the Act to perform only certain, limited duties . An independent counsel’s role is restricted primarily to investigation and, if appropriate, prosecution for certain federal crimes. Admittedly, the Act delegates to appellant “full power and independent authority to exercise all investigative and prosecutorial functions and powers of the Department of Justice,” § 594(a), but this grant of authority does not include any authority to formulate policy for the Government or the Executive Branch, nor does it give appellant any administrative duties outside of those necessary to operate her office. The Act specifically provides that, in policy matters, appellant is to comply to the extent possible with the policies of the Department. § 594(f). [28]

To be an “officer of the United States,” the position held must have a continuous duration and regular duties . For example, Germaine and Hartwell used words like “intermittent” and “occasional” to refer to the nature of the position’s “duties.” [29] Where the duties are episodic as opposed to regular, constant, and ongoing, that would indicate that the position is not an “officer” position, and is instead an employee, contractor, or agent. In Lucia , the Court held that the position (as opposed to its duties ) must be “continuing.” [30] Again, the Hartwell-Germaine test was a four-factor test, the position’s duration or continuity was one factor, and the position’s duties were a different, separate factor. The fact that the duties can be described as ongoing, as opposed to episodic, does not mean that the position itself is continuous, and will continue from its current holder to future successors.

Jack Smith’s position is not a continuing one. It fails the tests mandated by Buckley , Morrison , and Lucia .  Smith does not hold an “officer of the United States” position. And as such, he cannot prosecute Trump—or anyone else for that matter.

III. Has Congress appropriated money to pay the Special Counsel and his staff and contractors?

According to the Special Counsel, Congress has appropriated monies to pay the Special Counsel and his staff. The Special Counsel relies upon a note to 28 U.S.C. § 591 . The note states: “A permanent indefinite appropriation is established within the Department of Justice to pay all necessary expenses of investigations and prosecutions by independent counsel appointed pursuant to the provisions of 28 U.S.C. [§] 591 et seq. or other law.”

The Special Counsel’s reliance on this funding mechanism is problematic for several reasons. First, the note is not a numbered section of the United States Code. (The precise status of a “ statutory note ” is a complicated matter.) The Special Counsel argues that the note is part of the United States Code even if not a numbered provision. Second, Section 591 was part of the regime under the Ethics in Government Act (1978). Congress failed to reauthorize that act, and, as such, Section 591 expired. The Special Counsel argues that that the funding provision in the note survives Congress’s failure to reauthorize the statute with which it was codified. But it is not entirely clear how a “note” to Section 591 survives after Section 591 is no longer in effect. And third, the note is a funding mechanism for “independent counsels”—a position established by the prior independent counsel regime. The text of the note does not expressly reach today’s “special counsels,” which is how the Reno-era regulations refer to the position at issue in United States v. Trump . For the reasons we explain below, the positions of “independent counsel” and “special counsel” are not analogous.

The traditional purpose of Independent Counsels (under the 1978 act) and Special Prosecutors (as in Nixon ) was to prevent a particular conflict of interest: where the DOJ would investigate itself , the President, as well as the President’s family and close confidants. There would be a conflict in such cases because the DOJ is ultimately responsible to the President. In other words, prosecutors outside the usual chain of responsibility, and who enjoyed unusual independence, were needed so that DOJ could avoid internal conflicts—the conflicts that arise where the prosecutor investigates itself and/or those to whom the prosecutor is responsible. For example, Attorney General Garland’s decision to appoint a special counsel to investigate President Biden’s document case, as well as Hunter Biden’s criminal case, fits into this paradigm. Special Counsel Jack Smith explained this approach in his opposition brief:

Smith’s brief also relied on United States v. Stone (2019). [32] Stone relied upon the same GAO report discussed above, and the Stone court explained: “The [Ethics in Government Act] authorized the Attorney General to refer criminal matters involving certain high-level government officials, including the President, to a three-judge court, which would be responsible for the appointment of an independent investigating attorney.” [33]

Special Counsel Smith has not been asked to investigate the DOJ, the President, the President’s family or his close confidants. Special Counsel Smith indicted Trump after he was out of office for more than a year. At that time, he was not President—he was a former President. In other words, he was a private citizen. Indeed, not only was he charged after he was no longer President, but the charges in the Florida indictment relate exclusively to conduct that took place after he was President. As Smith explained in his own brief, the scope of “independent counsel” in Section 591’s note does not permit the Attorney General to fund any prosecution at his discretion via independent counsels, but only those “independent counsels” where the DOJ would face an internal conflict associated with the DOJ investigating a “high ranking government official.”

Given that Trump was not a “high ranking,” “high-level,” or any type of government official at the time he was indicted, and that the alleged conduct also took place after he was out of office, the DOJ faces no internal conflict. In these circumstances, the funding mechanism in Section 591’s note cannot be used to pay Smith, his employees, and his contractors. And if this argument is correct, all work by the Special Counsel’s office must cease—except, perhaps, that associated with making filings for reconsideration and appeal. We take no position here as to whether Smith’s continued work, particularly if Judge Cannon should rule against him, would trigger criminal or civil liability under the Anti-Deficiency Act, federal or state RICO, or other state offenses. Moreover, if Judge Cannon rules that Smith is not in fact a duly-appointed officer under federal law, should he be sued in state court, then any attempt to invoke the federal officer removal statute would be frustrated by Judge Cannon’s extant ruling. Indeed, such a removal action may automatically be referred to Judge Cannon’s courtroom as a related matter.

When pressed on this point, the Special Counsel stated that if the District Court should determine that the funding mechanism in Section 591’s note is not available to fund Jack Smith and his office, the DOJ is sure that other statutes provide a lawful means to fund the Special Counsel. However, counsel for the Special Counsel made reference to no specific federal statute that could lawfully fund Jack Smith and his office. To us, this sort of abstract “defense,” absent specificity, seemed highly irregular. [34]

United States v. Trump poses more than a few threshold legal questions. We do not suggest that all the answers to those questions line up neatly in former President Trump’s favor. But we do say that those lines of argument supporting a dismissal of the indictment are substantially more than frivolous; indeed, we believe that several of those arguments have considerable merit. These issues are of the variety regularly seen by federal courts—they are the sort of issues and arguments that reasonable minds may disagree. And unless we are mistaken, that is also, now, the position of the Special Counsel. [35]

* Seth Barrett Tillman is an associate professor in the Maynooth University School of Law and Criminology, Ireland / Scoil an Dlí ages na Coireolaíochta Ollscoil Mhá Nuad.

** Josh Blackman holds the Centennial Chair of Constitutional Law at the South Texas College of Law Houston, and the author of An Introduction to Constitutional Law: 100 Supreme Court Cases Everyone Should Know . We thank the editors and reviewers at HJLPP: Per Curiam . All errors remain ours.

[1] Brief of Professor Seth Barrett Tillman and Landmark Legal Foundation as Amici Curiae in Support of Defendant Trump’s Motion to Dismiss the Indictment, United States v. Trump, Case No. 9:23-cr-80101-AMC-BER (S.D. Fla. Mar. 21, 2024), ECF No. 410, 2024 WL 1214430, https://ssrn.com/abstract=4755563, https://tinyurl.com/3kju33w4; Motion for Leave of Professor Seth Barrett Tillman and Landmark Legal Foundation to Participate in Oral Argument as Amici Curiae in Support of Defendant Trump’s Motion to Dismiss the Indictment [ECF No. 326], United States v. Trump, Case No. 9:23-cr-80101-AMC-BER (S.D. Fla. May 30, 2024), ECF No. 590, 2024 WL 2833495 https://ssrn.com/abstract=4837841, https://tinyurl.com/3kju33w4; Trs. of Oral Arguments (June 21, 2024), ECF No. 635, 647–50, https://tinyurl.com/3kju33w4. The motion was decided. See United States v. Trump, Case No. 9:23-cr-80101-AMC, 2024 WL 3404555 (S.D. Fla. July 15, 2024), ECF No. 672, https://tinyurl.com/hk4z7e76.

[2] See U.S. Const. art. II, § 2.

[3] 418 U.S. 683 (1974).

[4] See United States v. Johnson, 921 F.3d 991, 1001 (11th Cir. 2019) (William Pryor, J.) (en banc) (“Although Johnson argues that Terry is inconsistent with the original meaning of the Fourth Amendment and that we should apply it narrowly to ‘limit[] the damage,’ we must apply Supreme Court precedent neither narrowly nor liberally—only faithfully.”); Jefferson County v. Acker, 210 F.3d 1317, 1320 (11th Cir. 2000) (“There is, however, a difference between following a precedent and extending a precedent.”).

[5] See 418 U.S. at 691 (“unique”), 697 (“uniqueness of the setting”).

[6] Id . at 694.

[7] Id . at 697 (emphasis added).

[8] 531 U.S. 98, 109 (2000) (“Our consideration is limited to the present circumstances . . . .”).

[9] See Nixon , 481 U.S. at 694–95, 694 n.8 (citing 38 Fed. Reg. 30738–39, as amended by 38 Fed. Reg. 32805).

[10] See Id. at 695 (characterizing the 1973 Bork regulations as having “the force of law”); cf. Allapattah Services, Inc. v. Exxon Corp., 362 F.3d 739, 765 (11th Cir. 2004) (suggesting that a Supreme Court holding is no longer controlling “where specific statutory language that had previously been interpreted by the Court is amended . . . .”).

[11] Nixon , 418 U.S. at 694 n.8 (quoting the underlying regulation).

[12] See 28 C.F.R. 600.7(d) (1999) (permitting a special counsel’s removal for “good cause”).

[13] See, e.g ., Bowsher v. Synar, 478 U.S. 714 (1986).

[14] 73 U.S. 385, 387 (1867).

[15] Id at 390.

[16] Id . at 393.

[17] 99 U.S. 508 (1879).

[18] 137 U.S. 310 (1890).

[19] 424 U.S. 1, 126 (1976); see supra note 3 (citing United States v. Nixon ).

[20] Id. at 126 n.162

[21] Id . at 126 (emphases added).

[22] 585 U.S. 237, 245 (2018).

[23] Id. at 245 (emphasis added).

[24] See also Id. at 269 (Sotomayor, J., dissenting) (characterizing Buckley’s “significant authority” test and the Lucia majority’s continuing position test as “two prerequisites to officer status” (emphasis added)).

[25] Morrison v. Olson, 487 U.S. 654, 672 (1988).

[26] Lucia , 585 U.S. at 245 (quotation marks omitted).

[27] Tr. of Oral Argument, 155:13–20 (June 21, 2024).

[28] Morrison , 487 U.S. at 671–72 (emphasis added).

[29] United States v. Germaine, 99 U.S. 508, 512 (1879); United States v. Hartwell, 73 U.S. 385, 393 (1867); see also In re Grand Jury Investigation , 315 F. Supp. 3d 602, 644 (D.D.C. 2018) (explaining that the special counsel’s work or duties are “not occasional, intermittent, or episodic” because the duties remain “ongoing and regular until complete”).

[30] Lucia , 585 U.S. at 237.

[31] Smith Brief at 20 (Mar. 7, 2024), ECF No. 374 (citing GAO, Special Counsel and Permanent Indefinite Appropriation , B-302582, 2004 WL 2213560, at *4 (Comp. Gen. Sept. 30, 2004)) (underscore added).

[32] 394 F. Supp. 3d 1 (D.D.C. 2019).

[33] Id. at 17 (emphasis added); see also Tr. of Oral Argument, 60 (June 21, 2024) (Pearce on behalf of the Special Counsel: “It is inherent in the effort to, on the one hand, ensure that—whether we call it an independent counsel or a Special Counsel—has adequate independence when a situation presents itself that requires the avoidance of conflict or somebody who can operate outside of the typical Justice Department, sort of, operations because it’s investigating the Justice Department itself or it’s investigating some sort of high-ranking or high-level political official .” (emphasis added)).

[34] Tr. of Oral Argument, 44 (June 21, 2024) (Pearce on behalf of Special Counsel: “[T]o the extent that the Court is seriously entertaining the notion that there is a constitutional or funding problem, I actually think it would behoove the Court and the parties to have some additional briefing.”).

[35] Tr. of Oral Argument, 46:7–8 (June 24, 2024) (“To be candid with the Court, we find [Tillman’s position] to be not a frivolous [one], but a . . . .”).

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About Harvard JLPP

The Harvard Journal of Law & Public Policy is published three times annually by the Harvard Society for Law & Public Policy, Inc., an organization of Harvard Law School students.

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