One of the most confounding changes to the new Bluebook edition is the new “Contrast with” signal. Its purpose is unclear; the long-established “Compare with” signal already includes elements of both comparing and contrasting. The structure of the “Compare with” signal is straightforward:

Compare [case A], and [case B], with [case C], and [case D].

One category of cases appears before the “with.” Another category appears after the “with.” The “with” itself facilitates a contrast between the two categories.

So how is the “Contrast with” signal different? Other than swapping out the word “compare” for “contrast,” The Bluebook does not say. This new signal will likely introduce even more confusion for legal writers who were already wary of using the “Compare with” signal.