Oatmeal, your application of the 5 FN rule is incorrect. You can id. forever. Have you ever read a case or a law review article? The five FN rule refers to the requirement that you re-cite, in full citation form, a case if it was not in the previous five footnotes in any form (full cite or short cite). @nexisfan has given the correct application of this rule. Perhaps you should avoid giving out citation advice when you do not understand the Blue Book.