Universal Citation

Universal Citation - US Courts

Below is a partial listing of the jurisdictions currently employing a universal citation standard. If your court has a universal citation standard that isn't listed below, please let us know!

ARIZONA

Action: Paragraph numbering of opinions from the Supreme Court and Court of Appeals.

Summary: All opinions, including opinion orders, issued by an AZ appellate court on or after January 1, 1998 will include paragraph numbers. When referring to specific portions or passages of these opinions, employ the paragraph numbers as pinpoint citations; and pinpoint citations to a case reporter service will be optional. In all other respects, the appellate courts' citations practices are not affected by this order.

See full text: Supreme Court of the State of Arizona, Administrative Order No. 97-67

ARKANSAS

Action: The Arkansas Judiciary Reporter of Decisions Style guide does not allow "vendor neutral" citations.

Summary: A note in the Style Guide under the case citation section mentions "electronic 'vendor neutral' citations have not been adopted and are not recognized. Another notation under the exaples for citing computer resources reads "The so-called 'vendor-neutral' citation format has not been approved by the Arkansas Supreme Court and should not be used."

See full text: Arkansas Judiciary Reporter of Decisions House Style Guide

COLORADO

Action: Allows publishers to number paragraphs following court guidelines.

Summary: In May, 1994 a policy was adopted by the Supreme Court of Colorado allowing pinpoint citations to be made using a page number from West's Pacific Reporter or a paragraph number in the opinion. Rather than design their own numbering system, the court has issued guidelines for publishers who wish to publish Supreme Court or Court of Appeals opinions to implement a paragraph numbering system.

See full text: Memo from Mac V. Danford, Supreme Court of Colorado

GUAM

Summary: Guam's Supreme Court has followed a neutral citation standard from its inception in 1996. Cases may be cited in the following format: (Year) Guam (Opinion Number).

Example:

Doe v. Smith, 2007 Guam 53

See also: Guam Supreme Court

LOUISIANA

Action: Change in citation rules to incorporate "uniform public domain citation" format to appellate court decisions, mandatory in court documents filed after July 1, 1994.

Summary: Opinions and actions issued by LA Supreme Court and Courts of Appeal after Dec. 31, 1993 should be cited according to a uniform public domain citation form which shall consist of: the case name, docket number excluding letters, court abbreviation, and month/day/year of issue; to be followed by a parallel citation to West's Southern Reporter. If a pinpoint citation is needed, the page number designated by the court shall follow the docket number and be set off with a comma and the abbreviation "p".

Examples:

Smith v. Jones, 93-2345 (La. 7/15/94); 650 So.2d 500

Smith v. Jones, 93-2345 (La. App. 1 Cir. 7/15/94); 660 So.2d 400

Smith v. Jones, 94-2345, p. 7 (La. 7/15/94); 650 So.2d 500, 504

See full text: Rules of the Supreme Court of Louisiana, Part G, Section 8

MAINE

Action: The Supreme Judicial Court of Maine will include a sequential number assigned to opinions for each calendar year and assign paragraph numbers.

Summary: Opinions issued on or after Jan. 1, 1997 shall include the calendar year and the sequential number assigned to the opinion. The paragraphs in the opinion will be numbered. The official publication of each opinion issued will include the sequential number in the caption of the opinion and the paragraph numbers assigned by the courts.

Examples:

Smith v. Jones, 1997 ME 7, 685 A.2d 110

Smith v. Jones, 1997 ME 7, ¶14, 685 A.2d 110

See full text: State of Maine Supreme Judicial Court Order, Docket No. SJC-216

MISSISSIPPI

Action: The Supreme Court and Court of Appeals shall assign paragraph numbers in all published opinions and will be cited (after July 1, 1997) to the case numbers assigned by the Clerk's office.

Summary: Cases shall be cited to either the Southern Reporter (and, in cases prior to 1967 the official Mississippi Reports) OR the case numbers as assigned by the Clerk for cases cited from and after July 1, 1997. If quotations appear they should be cited: a.) to the page in the Southern Reporter and/or the MS Reports b.) in cases decided from and after July 1, 1997 cited to the paragraph number of the decision after the case number assigned by the clerk's office c.) in cases decided from and after July 1, 1997 cited to the paragraph number of the decision in the Southern Reporter d.) in cases decided prior to July 1, 1997 cited to the paragraph number of the decision after the case number assigned by the clerk's office as the cases are added to the Court's Internet web site.

Examples:

Smith v. Jones, 95-KA-01234-SCT (Miss. 1997)

Smith v. Jones, 95-KA-01234-SCT(¶1) (Miss. 1997)

Smith v. Jones, 699 So. 2d 100 (C1) (Miss. 1997)

See full text: Mississippi Rules of Appellate Procedure, Rule 28 (e)

MONTANA

Action: From and after January 1, 1998 the Supreme Court will assign to all opinions and substantive orders a public domain or neutral format citation which will appear on the title page of each opinion.

Summary: At the time of issuance the Court will assign a citation which will include the case name, year of decision, 2 letter postal code, and a sequential number assigned by the court. Beginning with the first paragraph of text, each paragraph will be numbered consecutively beginning with a mark. In the case of opinions not to be cited as precedent ("unpublished") the consecutive court assigned number will be followed by an "N", cases which have be withdrawn or vacated will be designated with a "W", and cases which are amended will be appointed an "A". These citation formats are in addition to and supplement the current citation formats. The Montana Reports is the official reporter of the court and the court will continue to cite to the official reporter and the regional, Pacific, reporter in addition to the public domain, neutral format citation. In turn the State Reporter Publishing Company and West Group have been asked to publish the public domain, neutral format citation within the heading of each opinion. The court encourages the adoption and use of these formats in all briefs, memoranda and other documents filed with the court.

Examples:

Doe v. Roe, 1998 MT 12,286 Mont. 175,989 P2d. 1312

Doe v. Roe, 1998 MT 12,¶¶44-45,286 Mont. 175,¶¶44-45,989 P2d. 1312,¶¶ 44-45

Doe v. Roe, 1998 MT12N (unpublished opinions)

Doe v. Roe, 1998 MT 12W (withdrawn or vacated opinions)

Doe v. Roe, 1998 MT 12A (amended opinions)

Doe v. Roe, 1998 MT 12A,¶13a ( pinpoint cite for new paragraphs in an amended opinion)

Doe,¶¶44-45 (pinpoint cite)

See full text: Montana Court Uniform Rules (RTF)

NEW MEXICO

Action: The New Mexico Supreme Court granted a motion to adopt a vendor neutral citation for appellate opinions, New Mexico Statutes Annotates, Court Rules, and Uniform Jury Instructions as the official citations for all pleadings and other papers filed in the courts of the state of New Mexico.

Summary: On or after January 1, 1996, the Supreme Court clerk will publish all appellate opinions with vendor neutral citations, which will serve as the official citation for appellate opinions. Vendor neutral citation should be cited with the state reporter or the regional reporter. When citing subsequent history, the Supreme Court docket number should be substituted for a vendor neutral citation. Pinpoint citations will be to paragraph numbers when available.

When applying vendor neutral citations to New Mexico Statutes Annotated it is unnecessary to refer to "Cum. Supple." Or "Repl. Pamp.", rather reference should be made to the applicable date of enactment as set forth in the "History Note" following each statute.

Examples:

State v. Ray, 1998-NMSC-001 (Supreme Court)

State v. Ray, 1998-NMCA-001 (Court of Appeals)

State v. Ray, 1998-NMCA-001,¶2 (with pinpoint citation)

NMSA 1978, Section 5 (1999) (NM Statutes Annotated)

Rule 78 NMRA 1998 (NM Rules)

UJI 123 NMRA 1998 (NM Uniform Jury Instructions)

See full text: New Mexico Citation Rules

NORTH DAKOTA

Action: New Mexico Supreme and Appellate Courts ordered that decisions after Jan. 1, 1997 would include a medium-neutral case citation in the initial citation, with paragraph numbers assigned to decisions for pinpoint cites.

Summary: After January 1, 1997 when available, initial citations must include the volume and initial page number of the North Western Reporter. The initial citation after this date must also include a reference to the calendar year in which the decision was filed, followed by court designation of ND or ND App, followed by a sequential number assigned by the Clerk of the Supreme Court. A paragraph citation should be placed following the sequential number assigned to the case.

Examples:

Smith v. Jones, 1997 ND 15, 600 N.W.2d 900

Smith v. Jones, 1997 ND 15,¶21, 600 N.W.2d 900

Smith, 1997 ND 15,¶21-25, 600 N.W.2d 900

Id. at¶15

See full text: ND Supreme Court Rules, Rule 11.6 Medium-Neutral Case Citations

NORTHERN MARIANA ISLANDS

Action: On March 13, 2001 the Supreme Court of the Commonwealth of the Northern Mariana Islands issued General Order No. 2004-100 adopting the universal citation format.

Summary: Per General Order 2001-100, NMI Supreme Court opinions are to be cited in the following format: (Year of Issuance) MP (Sequential Opinion Number). Pinpoint citations are to be made to the paragraph number designating the precise location of the cited language. The universal citation system was retroactively applied to Supreme Court decisions dating back to 1996 via a series of subsequent orders.

Example:

Francis v. Welly, 1999 MP 26

See full text: General Order 04-100 (see first paragraph)

See also: NMI Style Guide

OHIO

Action: OIn July 2002, the Ohio Supreme Court Reporter ordered the implementation of a media-neutral citation system.

Summary: In-state references to decisions issued after 2002 must include a vendor-neutral citation constructed as follows: Year-Ohio-Decision Number. Pinpoint cites should be made to paragraph numbers assigned by the court reporter or, for pre-2002 decisions, to the official report. Also, in-state references to decisions appearing in the Ohio State Reports, Ohio Appellate Reports, or Ohio Miscellaneous Reports should (if possible) include citations to those reports.

Example:

Office of Disciplinary Counsel v. Shrode, 95 Ohio St. 3d 137, 2002-Ohio-1759, 766 N.E.2d 597, at ¶8.

See full text: Revisions to the Manual of Citations

See also: Ohio Court Rules

OKLAHOMA

Action: Published opinions of the OK Supreme Court and Court of Civil Appeals will bear as an official cite a paragraph citation form after May 1, 1997.

Summary: The court designation for the Supreme Court is "OK" when the paragraph citation form is used. The designations for the Court of Civil Appeals is "OK CIV APP" and for the Court of Appeals of Indian Territory is "IT" when the paragraph citation form is used to cite the opinions of those courts. Prior to May 1, 1997 parallel citation to Oklahoma Reports should not be made when the Supreme Court's official paragraph citation form is used. After May 01, 1997 opinions filed shall be cited by reference to the Supreme Court's official paragraph citation form with subsequent parallel citation to Pacific Reporters required.

Examples:

Skinner v. Braum, 1997 OK 11, 890 P.2d 922

Skinner v. Braum, 1997 OK 11, ¶9, 890 P.2d 922

Skinner v. Braum, 1997 OK 11, ¶9, 890 P.2d 922, 925

Smith v. Braum, 1997 OK CIV APP 11, 890 P.2d 922 (OK Court of Civil Appeals)

Smith v. Braum, 1997 IT 11, ¶9

See full text: OK Supreme Court Rules, Rule 1.200

PENNSYLVANIA SUPERIOR COURT

Action: Effective January 1, 1999, opinions issued by the Pennsylvania Superior Court must contain a Universal Citation.

Summary: All opinions issued by the Pennsylvania Superior Court contain a universal citation in the following format: (Year) PA Super (Court-issued number). The opinions also have numbered paragraphs to be used for pinpoint citations. Citations made to opinions not yet issued by the Atlantic 2d must use the Universal Citation. Once the official citation has been issued, however, citation is to be made only to the official citation and not the Universal Citation.

Examples:

Jones v. Smith, 1999 PA Super 1

Jones v. Smith, 1999 PA Super 1, ¶15

See full text: Notice to the Bar

SOUTH DAKOTA

Action: The South Dakota Supreme Court, the US District Court for SD, and the US Bankruptcy Court for SD have all adopted the "universal citation system" for identifying their written opinions.

Summary: The initial citation of any published opinion of the Supreme Court released on or after January 1, 1996 in a brief, memorandum, or other document filed with the Court and the citation in the table of cases in a brief shall include a reference to the calendar year in which the decision was announced, the Court designation of "SD", and a sequential number assigned by the Clerk of the Supreme Court. Citation to specific portions of the opinion will be made to paragraph numbers. When available, initial citations shall include the volume and initial page number of the North Western Reporter.

Examples:

Hoogestraat v. Barnett, 2001 SD 104

Erickson v. County of Brookings, 1996 SD 1, 541 NW2d 734

Smith v. Jones, 1996 SD 15, ¶21, 600 NW2d 900 (with pinpoint citation)

Yankton Sioux Tribe v. Janklow, 2001 DSD 24 (District Court of SD)

In re Greene, 2001 BkDSD 16 (Bankruptcy Court of SD)

See full text: SD Unified Judicial System Court Procedure Section 15-26A-69.1 (scroll down)

TENNESSEE

Action: Supreme Court of Tennessee denied petition by the Tennessee Bar Association to approve a "Citation System for Tennessee Appellate Decisions".

Summary: The court invites the Bar Association to file another proposal for a universal citation system when it determines that there is a greater consensus among citation experts and national legal organizations regarding the components and form of a universal citation system.

See full text: In re: Petition of TN Bar Association for the Approval of Citation System...

UTAH

Action: The Utah Supreme Court and Utah Court of Appeals adopt a universal citation form effective March 1, 2000.

Summary: The initial citation of any published opinion of the Utah Supreme Court or Utah Court of Appeals released on or after January 1, 1999 in any brief, table of cases in the brief, memorandum, or other document filed with these courts shall include case name, the year the opinion was issued, identification of the court that issued the opinion, and the sequential number assigned by the respective court. A comma and then a paragraph symbol will denote pinpoint citations. Initial citations should also include either the Utah Advance Report Citation or the volume and initial page number of the Pacific Reporter in which it is published. The year the case was published and the parallel page number for pinpoint citation to the Pacific Reporter is not required since the paragraph numbers will be included in the Pacific Reporter and the year will be evident from the initial citation.

Examples:

Smith v. Jones, 1999 UT 16 (before publication in Utah Advance Reports)

Smith v. Jones, 1999 UT App 16

Smith v. Jones, 1999 UT 16, 380 Utah Adv. Rep. 24 (before publication in Pacific Reporter)

Smith v. Jones, 1999 UT 16, 998 P.2d 250 (after publication in Pacific Reporter)

Smith v. Jones, 1999 UT 16, ¶21, 998 P.2d 250 (pinpoint citation after publication in Pacific Reporter)

WISCONSIN

Action: In the Supreme Court of Wisconsin and the Court of Appeals, the official publication of each opinion, rule, order, and other item to be published on or after January 1, 2000, shall set forth the public domain citation of the opinion, rule, order, or other item and shall include the paragraph numbering of the opinion.

Summary: "Public domain citation" means the calendar year in which an opinion, rule, order, or other item that is to be published is issued or ordered to be published, whichever it later, followed by the designation of the court, followed by the sequential number assigned by the clerk of the court. Citation to specific portions of an opinion issued on or after January 1, 2000 shall be by reference to paragraph numbers. Citation to published opinions to the courts in both table of cases and initial citation shall include in the following order: public domain citation (if it exists), volume/page number of the WI Reports, and volume/page number of the North Western Reporter.

Examples:

Smith v. Jones, 2000 WI 14

Smith v. Jones, 2000 WI App 9

Smith v. Jones, 2000 WI 14, 214 Wis. 2d 408,595 N.W.2d 346

Smith v. Jones, 2000 WI 14, ¶6

Smith v. Jones, 2001 WI App 9, ¶17

See full text: Order No. 95-01 In the Matter of the Amendment of Supreme Court Rules: SCR Chapter 80

WYOMING

Action: In October 2000, the Supreme Court of the State of Wyoming ordered adoption of a public domain or neutral-format citation format.

Summary: The court shall assign to all opinions and orders designated for publication, a citation which shall include the calendar year in which the opinion is issued, followed by the Wyoming postal Code, followed by a consecutive number beginning each year with "1". This citation will appear on the title page of each opinion issued by the court. All publishers of Wyoming Supreme Court materials are requested to include this public domain, neutral-format citation within the heading of each opinion they publish. Beginning with the first paragraph of text, each paragraph of such opinions will be numbered consecutively beginning with a ¶ symbol followed by an Arabic numeral, flush with the left margin, opposite the first word in the paragraph. All publishers are requested to include these paragraph numbers in each opinion they publish. In cases of opinion not to be cited as precedent, the consecutive number in the public domain citation will be followed by the letter "N" to indicate that the opinion should not be cited as precedent. In the case of withdrawn or vacated order, the letter "W" will be assigned. For amended opinions the public domain citation shall be the same as the original public domain citation, but followed by a letter "A". In these amended opinions any additional paragraphs will be numbered with the same paragraph number as the original with a lower case letter added behind the number. If the paragraph is deleted then the paragraph numbering will remain the same as the original, skipping the deleted paragraph in the numbering system. For cases decided between January 1, 2001 and December 31, 2003 a proper citation will also include the volume and initial page number of the West Pacific Reporter. For cases decided after December 31, 2003, reference to the Pacific Reporter in which the opinion is published shall be optional. The Wyoming Reporter will remain the official reporter for this court's opinions.

Examples:

Doe v. Roe, 2001 WY 12,989 P.2d 1312 (Wyo. 2001) (between 01/01/01 and 12/31/03)

Doe v. Roe, 2001 WY 12, ¶44, 989 P.2d 1312, ¶44 (Wyo.2001)

Doe v. Roe, 2003 WY 12 (after Dec. 31, 2003)

Doe v. Roe, 2003 WY 12, ¶44 (after Dec. 31, 2003)

See full text: In the Matter of Adopting a Public Domain, Neutral-Format Citation Format

COURT OF THE SIXTH CIRCUIT

Action: The Sixth Circuit court has adopted an "Electronic Citation System".

Summary: Beginning with opinions issued by the court in 1994, a special electronic citation has been assigned to each opinion designated for publication by the court. The citation will be at the top of the opinion along with its computer file name. The format of the citation includes the case name, year issued, FED identifier, unique opinion number, "P" for published, pinpoint cite to slip opinion page number, and court. The Court has not adopted any rules or guidelines concerning the use of the citation and its use is not required in citing to the court.

Examples:

Jones v. Smith, 1994 FED App. 1234P at 12 (6th Circuit)

See full text: Sixth Circuit Electronic Citation