Rule B12.1.2 governs the citation of state statutes. The first time a statutory compilation is cited, it should be structured as follows:
[State Code Abbreviation] § [Section #] (Year of Code Edition)
Rule B12.1.2 requires citation to an official version of the state code whenever possible. The citation style for each state’s official code is provided in The Bluebook table T1.3. So, the treble-damages provision of Chapter 75 should be cited as follows:
N.C. Gen. Stat. § 75-16 (2017).
Once you have provided a full citation, subsequent references to the General Statutes can be shortened by using “id.,” if the immediately prior citation was to the General Statutes, or by simply leaving off the year of publication.
The North Carolina General Statutes are published by LexisNexis every other year on odd years. However, the new edition is not released until beginning of the following (even-numbered) year, so even during an odd-numbered year, citing to the current year is probably incorrect. For example, the 2017 edition, which at the time of this post is the current edition of the General Statutes, should be cited until around January 2020, when the 2019 edition will be published.
A Practical Tip
How many times have you seen the General Statutes abbreviated in citations as “N.C.G.S.”? Well, according to the The Bluebook, which requires the use of the abbreviation “N.C. Gen. Stat.,” that abbreviation is incorrect. However, when citing sources in an important court filing, it is a good practice to verify, when possible, how the court cites the same resource. If the judge uses “N.C.G.S.” in his or her citations to the North Carolina General Statutes, he or she is unlikely to give a second glance to a party’s filing that does the same.
H/T to Scottie Lee for the information about the publication date of the General Statutes.