Citation, Documentation of Sources
Q. If your first footnote is a specific source, then you have another source for the second footnote, then your third footnote is from the same source as footnote 1, do you just say “Ibid. from footnote 1”? Or do you rewrite it out?
A. Two things to know about ibid. when using it in a note: it must always refer to the note immediately before it; and the note it refers to must have only one citation in it. In note 3, for example, you can use ibid. only to refer to note 2, assuming that note 2 contains only one citation. To refer to note 1 (or to refer to a citation in note 2 when note 2 contains more than one citation), you must repeat the citation (although you can shorten it to just author and a short title). Please read about the use of ibid. at CMOS 14.34. (Note that Chicago now prefers shortened citations over ibid.)