Citators are divided into sections called divisions. All of the cited references from a single reporter or other individual source of legal authority are listed in a single division. Different series of reporters appear in separate divisions. For example, Shepard's North Eastern Reporter Citations has one division for the North Eastern Reporter and a separate division for the North Eastern Reporter, Second Series . A case, statute, regulation, or other legal authority that retains its value as precedent.
Legal authority is either primary or secondary.
A primary legal authority is a case, statute, regulation, or other authority supported by governmental power. A secondary legal authority is a treatise, law review article, or other source that comments on the law but is not supported by governmental power. A secondary authority may be used in an argument to persuade the court, however, and, if successful, the court may place its primary authority behind a secondary authority and adopt the secondary authority as precedent. Any written opinion, whether or not it is published in a reporter, may be referred to as a case by its case name. These citations are called parallel citations.