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A legal reference may be included in the reference list in full, with a numbered citation in the text, or it may be included in the text parenthetically and not included in the reference list. In scholarly articles, a full citation in the reference list is preferred, but in a news article or book review, for example, a parenthetical citation in the text might be adequate. In a leading decision on informed consent, the California Supreme Court stated …. In the case of Cobbs v Grant1 …. This reference would then appear in the reference list as follows: 1. Cobbs Less