Case citation
Case citation is a system used by legal professionals to identify past court case decisions, either in series of books called reporters or law reports, or in a neutral style that identifies a decision regardless of where it is reported. Case citations are formatted differently in different jurisdictions, but generally contain the same key information. A legal citation is a "reference to a legal precedent or authority, such as a case, statute, or treatise, that either substantiates or contradicts a given position." Where cases are published on paper, the citation usually contains the following information: In some report  series, for example in England, Australia and some in Canada, volumes are not numbered independently of the year: thus the year and volume number (usually no greater than 4) are required to identify which book of the series has the case reported within its covers. In such citations, it is usual in these jurisdictions to apply square brackets "" to the year (which may not be the year that the case was decided: for example, a case decided in December 2001 may have been reported in 2002). The Internet brought with it the opportunity for courts to publish their decisions on  websites and most published court decisions now appear in that way. They can be found through many national and other websites, such as WorldLII and AfricanLII, that are operated by members of the Free Access to Law Movement. The resulting flood of non-paginated information has led to numbering of paragraphs and the adoption of a medium-neutral citation system. This usually contains the following information: Rather than utilizing page numbers for pinpoint references, which would depend upon particular printers and browsers, pinpoint quotations refer to paragraph numbers. Pronunciation of case titles. In common law countries with an adversarial system  of justice, the names of the opposing parties are separated in the case title by the abbreviation "v" (usually written as "v" in Commonwealth countries and always as "v." in the U.S.) of the Latin word "versus", which means "against". When case titles are read out loud, the "v" can be pronounced, depending on the context, as "and", "against", "versus", or "vee". Commonwealth pronunciation. Most Commonwealth countries follow English legal style: American pronunciation. In the United States, there is no consensus on the pronunciation of the abbreviation "v." This has led to much confusion about the pronunciation and spelling of  court cases: During oral arguments in "Planned Parenthood v. Casey" (1992), the participants demonstrated the lack of consensus on the pronunciation of ""v."", using different pronunciations. Solicitor General Ken Starr even managed to use all three of the most common American pronunciations interchangeably: Australia. Legal citation in Australia generally mirrors the methods of citation used in England. A widely used guide to Australian legal citation is the "Australian Guide to Legal Citation" (commonly known as AGLC), published jointly by the "Melbourne University Law Review" and the "Melbourne Journal of International Law". The standard case citation format in Australia is: As  in Canada, there has been divergence among citation styles. There exist commercial citation guides published by Butterworths and other legal publishing companies, academic citation styles and court citation styles. Each court in Australia may cite the same case slightly differently. There is presently a movement in convergence to the comprehensive academic citation style of the Australian Guide to Legal Citation published jointly by the "Melbourne University Law Review" and the "Melbourne Journal of International Law". Neutral citation. Australian courts and tribunals have now adopted a neutral citation standard for case law. The format provides a naming system that does not  depend on the publication of the case in a law report. Most cases are now published on AustLII using neutral citations. The standard format looks like this: So the above-mentioned "Mabo" case would then be cited like this: "Mabo v Queensland (No 2)"  HCA 23. There is a unique court identifier code for most courts. The court and tribunal identifiers include: Canada. Section::::"The Canadian Guide to Uniform Legal Citation". There are a number of citation standards in Canada. Many legal publishing companies and schools have their own standard for citation. Since the late 1990s, however, much of the  legal community has converged to a single standard—formulated in "The Canadian Guide to Uniform Legal Citation / Manuel canadien de la référence juridique", commonly known as the "McGill Guide" after the "McGill Law Journal", which first published it. The following format reflects this standard: Broken into its component parts, the format is: The "Style of Cause" is italicized as in all other countries and the party names are separated by "v" (English) or "c" (French). Prior to 1984 the appellant party would always be named first. However, since then case names do not switch order when the case is appealed . Undisclosed parties to a case are represented by initials (e.g., "R v RDS"). Criminal cases are prosecuted by the Crown, which is always represented by "R" for "Regina" (queen) or "Rex" (king). Reference questions (advisory opinions) are always entitled "Reference re" followed by the subject title. If the year of decision is the same as the year of the report and the date is a part of the reporter's citation, then the date need not be listed after the "style of cause". If the date of the decision is different from the year of the report, then both should  be shown. Where available, cases should be cited with their neutral citation immediately after the "style of cause" and preceding the print citation. For example, This format was adopted as the standard in 2006, in the sixth edition of the McGill Guide. Prior to this format, the opposite order of parallel citation was used. The seventh edition of the McGill Guide, published 2010-08-20, removes most full stop/period (".") characters from the citations, e.g., a citation to the Supreme Court Reports that previously would have been  1 S.C.R. 791, is now  1 SCR 791. Most full stops  are also removed from styles of cause. The seventh edition also further highlights the significance of neutral citations (i.e., tribunal-assigned citations that are publisher-independent). Neutral citation. In 1999 the Canadian Judicial Council adopted a neutral citation standard for case law. The format provides a naming system that does not depend on the publication of the case in a law report. The standard format looks like this: Court identifiers. There is a unique court identifier code for most courts. Denmark. Denmark has no official standard or style guide governing case citation. However, most case citations include the same elements . Published decisions. Citations of decisions published in a reporter usually consist of the "name or abbreviation of the reporter", the "year or volume", the "page number" where the decision begin (sometimes followed by an "identifying number" if more than one judgment is on a page), as well as the "name or abbreviation of the court which decided the case". As an example, the "Aalborg Kloster-judgment", a precedent-setting Supreme Court judgment regarding strict liability, is published in Ugeskrift for Retsvæsen volume 1968 as the second judgment on page 84. A citation of this case could take the form , , , or  something similar. In this case "U", "UfR" and "Ugeskrift for Retsvæsen" identify the reporter, "1968" identifies the year or volume, "84" identifies the starting page, "/2" indicates that the judgment is the second one on that particular page, and "H" identifies the court which decided the case. Certain reporters, such as Tidsskrift for Skatter og Afgifter, do not identify published decisions by page number, but by a serial number. Citations to these reporters use the serial number in place of a page number. Unpublished decisions. If a decision has not been published in a reporter, more identifying information is needed . Generally, citations to unreported cases involve the "name of the court", the "date of the decision" and the "case number" assigned by the court. For example: Sø- og Handelsrettens dom af 3. maj 2018 i sag nr. V-17-17 (The Maritime and Commercial Court's judgment of May 3 in case no. V-17-17). Certain authors format these citations to mimic the "short citation" of published cases. Neutral citations and the ECLI. The Danish Court Administration is currently working on a public database which will make all judgments available to the public (currently only the Supreme Court as well as  the Maritime and Commercial Court do this). The database is expected to implement the European Case Law Identifier, which will make uniform, neutral citations of decisions possible. Germany. In Germany there are two types of citation: the full citation of a case and its shortened form. In e.g. scientific articles, the full citation of a particular case is only used at its first occurrence; after that, its shortened form is used. In most law journals, the articles themselves only use the shortened form; the full citations for all articles sometimes are summarized at the beginning of that journals edition. A  third type (yet not too widely spread) is the citation by using the European Case Law Identifier, a ″neutral″ citation system introduced by the Council of the European Union in 2011, which Germany is participating in. Federal Constitutional Court of Germany. The most important cases of the Federal Constitutional Court of Germany are published by the court in its official collection. This collection is abbreviated "BVerfGE", whereas "BVerfG" is short for "Bundesverfassungsgericht", the German court name, and "E" stands for "Entscheidung" (decision). Starting in 2004, the court also publishes the BVerfGK collection, containing decisions made only by a "Kammer", a  specific part of the court. The so-called for example could be cited in full and in short. For the meaning of the different case numbers of the BVerfG see . If decisions are not yet published by the court, or will not be published at all, law journals can be cited, e.g., Where "NJW" stands for the law journal , 2009 is the year, 1234 the page of the beginning and 1235 the cited page(s) – "f." stands for "seq.". In general, citations of the official collections are preferred. Federal Court of Justice of Germany. The Federal Court of Justice of Germany  (Bundesgerichtshof, short BGH) publishes the official collections "" for decisions in penal law and "" for those in private law. The e.g. would be cited in full and in short (in this example, not a specific page but the case as such is cited; "ff." means "sqq."). Other federal courts. The official collection of the Federal Social Court of Germany (Bundessozialgericht, BSG) is abbreviated "BSGE". The official collection of the Federal Finance Court of Germany (Bundesfinanzhof, BFH) is "BFHE". The official collection of the Federal Labor Court of Germany (Bundesarbeitsgericht, BAG) is "BAGE". The official collection of the Federal Administrative Court of  Germany (Bundesverwaltungsgericht, BVerwG) is "BVerwGE". Other courts. For other courts, generally the same rules apply, though most do not publish an official collection, so they must be cited from a law journal. European Case Law Identifier. According to the ECLI system the "Volkszählungsurteil" would be cited as and the "Katzenkönigfall" as India. India's vast federated judicial system admits to a large number of reporters, each with their own style of citation. There are over 200 law reports in India – subject-wise and state (province)-wise, authorized and unauthorized. Supreme Court of India. The official reporter for Supreme Court decisions is  the Supreme Court Reports. These reports however lag behind other journals in the speed of reporting. While decisions themselves are uploaded by the Supreme Court itself on "www.courtnic.nic.in", the edited versions with headnotes in the official reporter take years to compile. However, some reporters have been authorised to publish the Court's decisions. The "All India Reporter" (AIR) is an old and respected reporter that, in addition to the Supreme Court, also reports decisions of the various State High Courts. Other popular reporters include "Supreme Court Cases", which has become the most cited report in the Supreme Court, the "Supreme  Court Almanac", and "Judgements Today". "Sebastian Hongray v. Union of India": A citation of the "Supreme Court Almanac": A citation in "Judgements Today": The "Supreme Court Cases (SCC)" published supplementary reports for a few years in the early 1990s. Those citations looked like this: The SCC also have a separate series of subject-based reporting of the decisions of the Supreme Court: High Courts. The "All India Reporter" (AIR) is the most popular nationwide reporter for decisions of the High Courts. An AIR High Court citation looks like: "Surjya Kumar Das v. Maya Dutta" AIR 1982 Cal 222, where "Cal  refers to the Calcutta High Court in Kolkata. This is a uniform style for AIR High Court reports. Only the shortened indicator of the forum changes for different High Courts. The Calcutta Weekly Notes" is the oldest continuously published law journal in India having uninterrupted publication since 1896 reporting reportable decisions of the High Court at Calcutta. Reports are cited in the style 105 CWN 345 where 105 refers to the volume number calculated at one volume per year from the initial volume, which had been published in 1896. National Judicial Reference System (NJRS). National Judicial Reference System (NJRS) is  a project started by the Income-tax Department, Government of India. It has been envisaged as a tool to achieve efficiency in the tax litigation process of Income Tax Department (ITD). Within this project the Judicial Research & Reference System (JRRS) – JRRS is a repository of judicial orders as a single, indexed, searchable, cross-linked, database of Judgments / orders of ITAT, Authority of Advance Ruling (AAR), HC and SC. The Citation nomenclature followed within NJRS : This Citation further allows to add the Authority where the judgment / order was pronounced. New Zealand. The standard case citation format in New Zealand is: Several  leading law reviews in New Zealand have also adopted the "Australian Guide to Legal Citation" (AGLC) such as the "Canterbury Law Review". The AGLC style is also rather similar to citation style in New Zealand. Reporters. Additionally, a number of other report series exist for specialist areas such as Family, Employment and Tax Law. Neutral citation. New Zealand courts and tribunals have begun to adopt a neutral citation standard for case law. The format provides a naming system that does not depend on the publication of the case in a law report. The standard format looks like this: There is  a unique court identifier for each court or tribunal. These identifiers are: Where both a neutral citation and a reporter citation exist, the neutral citation should come first e.g. "R v AM"  NZCA 114,  2 NZLR 750 Norway. The Norwegian standard case citation format for published court decisions is: where: Philippines. Despite the long-standing civil law tradition in the Philippines, reliance on judicial precedents has become indispensable since the period of American rule. Supreme Court decisions are expressly recognized as part of the internal law, and are thus frequently cited in court decisions and legal pleadings. Though  there is only one Supreme Court in the Philippines, the citation of its decisions varies, depending on which reporter of a case is relied on by the person citing that case. Supreme Court. Section::::"Philippine Reports". The "Philippine Reports" is the official reporter of decisions of the Supreme Court of the Philippines. The standard format for citation of the "Philippine Reports" is: where: As of present, Philippine cases are contained in quarterly issues.The Supreme Court Reports Annotated or SCRA are cited as such: Juarez v. Court of Appeals 214 SCRA 475 where 214 is the volume of the book, and  475 is the page number. There are already over 700 SCRAs in circulation. Section::::"Supreme Court Reports Annotated". In the last few decades, the "Philippine Reports" has suffered from production problems, resulting in long delays in publication, as well as significant gaps within its published series. As a result, the privately published "Supreme Court Reports Annotated" (published by Central Professional Books, Inc.) has become more widely used than the "Philippine Reports", even by the courts. The proper format for citation of the "Supreme Court Reports Annotated" is: where: When citing cases not yet reported in the SCRA or "Philippine Reports", the  above citation without reference to the SCRA is preferred (i.e., "Fortich v. Corona", G.R. No. 131457, 24 April 1988) Lower court decisions. As there are no official or unofficial reporters that regularly publish decisions of the Court of Appeals and other lower courts, citation of their decisions hews to the same format as cases not reported either in the Philippine Reports or the SCRA. Thus: (case name), (docket number), (date of promulgation of decision). For the Court of Appeals, docket numbers begin as CA-G.R. No., followed by either CR for criminal, CV for civil, and SP for the "Special  Cases Section". Switzerland. Citations vary by court and by language. Cases of the Swiss Federal Supreme Court are cited as follows: Officially published cases are cited as "BGE 133 II 292 [E. 3.2 S. 296]" (German: "Bundesgerichtsentscheide") or "ATF 133 II 292 [consid. 3.2 p. 296]" (French: "arrêts du tribunal fédéral"). In this example, 133 is the annual issue of the court reports, II the part indicating the division of the Court, and 292 the page on which the decision begins. Optionally, "E. 3.2" and "S. 296" are the section and page specifically cited. Supreme Court decisions not selected for  official publication are cited as "Urteil [des Bundesgerichts] 5C.260/2006 vom 30. März 2007" or "arrêt [du Tribunal fédéral] 5C.260/2006 du 30 mars 2007" respectively. In this example, 5C is the division of the Court, 260 the case number and 2006 the year in which the case was opened. The citation style for cases of the inferior federal courts of Switzerland is similar. United Kingdom. Neutral citation. Since 2001, judgments in the House of Lords, Privy Council, Court of Appeal and Administrative Court have been issued with neutral citations. This system was extended to other parts of the High Court in  2002. Judgments with neutral citations are freely available on the British and Irish Legal Information Institute website (www.bailii.org). Neutral citations identify judgments independently of any series of reports, and cite only parties, year of judgment, court and case number. For example, "Rottman v MPC"  UKHL 20 identifies the 20th judgment in 2002 in the UK House of Lords. UKHL stands for UK House of Lords. EWHC and EWCA identify the England and Wales High Court and Court of Appeal respectively. These abbreviations are generally followed by an abbreviation indicating the court or division (e.g. Admin, Ch, Crim, Pat). How  to cite a case. If a neutral citation is available for a judgment, it should immediately follow the party names. If the judgment has also been reported in a law reports series, follow the neutral citation with the "best report", which is usually from the official Law Reports series (Appeals Cases – AC, Chancery – Ch, Family – Fam, Queen's Bench – QB etc.). The case of "Rottman v MPC" was reported in the Appeals Cases, so the citation should be: This means that a report of the case and the judgment can be found in the 2002 volumes, vol 2, of the  Law Reports series called Appeals Cases, beginning at page 692. To cite a particular paragraph from the judgment, add the paragraph number in square brackets at the end of the citation: If a case is not reported in the Law Reports, the next best report is the Weekly Law Reports (e.g.  2 WLR 1315), and then the All England Reports (e.g.,  2 All ER 865). In some situations, it might be preferable to cite a specialist series, e.g., "Rottman v MPC" was also cited in the Human Rights Law Reports, at  HRLR 32. For cases before 2001 , cite the best report. If referring to a particular page of the judgment, give that page number after the page number on which the report begins. The following citation refers to page 573 of the "Donoghue v Stevenson" judgment: England and Wales. The standard case citation format in England and Wales is: In England and Wales as with certain Commonwealth countries, the abbreviation "R" for "rex" (king) or "regina" (queen), is used for cases in which the state is a party (typically criminal cases or judicial review cases). If the Attorney General for England and Wales or the Director of  Public Prosecutions (England and Wales) prosecute the case, the abbreviation “AG” or “DPP” will be used instead of “R” Square brackets "[ ]" are used when the year is essential to locating the report (e.g., the official law reports either—as with "Donoghue v Stevenson", above—do not have volume numbers or, if there are multiple volumes in a single year, they are numbered 1, 2, etc.). Round brackets "( )" are used when the year is not essential but is useful for information purposes, e.g., in reports that have a cumulative volume number such as "R v Dudley and Stephens", above. Law Reports . The term "reporter", meaning a law report or a series of them, is not widely used in England and Wales. Before 1865, English courts used a large number of privately printed reports, and cases were cited based on which report they appeared in. (This system was also used in the United States and other common law jurisdictions during that period.) Two main unofficial law reports report all areas of law: the "Weekly Law Reports" (WLR) and the "All England Reports" (All ER). In addition, a number of unofficial specialist law reports focus on particular areas, e.g., "Entertainment and Media Law  Reports" (EMLR) or the "Criminal Appeal Reports" (Cr App R). For the citation of "The Law Reports" of the Incorporated Council of Law Reporting, see Law Reports. These have been published since 1865. They have always been split into a number of different series, the current series being the Appeal Cases (AC), Chancery (Ch), Family (Fam), and Queen's Bench (QB) (or King's Bench—KB—depending on the monarch of the time). These four series are cited in preference to all others in court. The table below is an incomplete list of law reports other than "The Law Reports , nominate reports and reprints. The table below is a list of series that are reprints of earlier reports. For nominate reports, see Nominate reports. Scotland. The standard case citation formats in Scotland are: The Supreme Court has issued a practice note on the use of neutral citation. The Scots Law Times" is cited as "SLT". United States. The standard case citation format in the United States is: where: Case citations are used to find a particular case, both when looking up a case in a printed reporter and when accessing it via the Internet or services such as LexisNexis or  Westlaw. This format also allows different cases with the same parties to be easily differentiated. For example, looking for the U.S. Supreme Court case of "Miller v. California" would yield four cases, some involving different people named Miller, and each involving different issues. Supreme Court of the United States. Cases from the Supreme Court of the United States are officially printed in the "United States Reports". A citation to the "United States Reports" looks like this: Many court decisions are published in more than one reporter. A citation to two or more reporters for a given court decision is called  a "parallel citation". For U.S. Supreme Court decisions, there are several unofficial reporters, including the "Supreme Court Reporter" (abbreviated S. Ct.) and "United States Supreme Court Reports, Lawyers' Edition" (commonly known simply as "Lawyers' Edition") (abbreviated L. Ed.), which are printed by private companies and provide further annotations to the opinions of the Court. Although a citation to the latter two is not required, some attorneys and legal writers prefer to cite all three case reporters at once: The "2d" after the L. Ed. signifies the second series of the "Lawyers' Edition". United States case reporters are sequentially numbered, but  the volume number is never higher than 999. When the 1,000th volume is reached (the threshold in earlier years was lower), the volume number is reset to 1 and a "2d" is appended after the reporter's abbreviation. Some case reporters are in their third series, and a few are approaching their fourth. Some very old Supreme Court cases have odd-looking citations, such as "Marbury v. Madison", 5 U.S. (1 Cranch) 137 (1803). The "(1 Cranch)" refers to the fact that, before there was a reporter series known as the "United States Reports" compiled by the Supreme Court's  Reporter of Decisions, cases were gathered, bound together, and sold privately by the Court's Reporter of Decisions. In this example, "Marbury" was first reported in an edition by William Cranch, who was responsible for publishing Supreme Court reports from 1801 to 1815. Such reports, named for the individual who gathered them and hence called "nominative reports", existed from 1790 to 1874. Beginning in 1874, the U.S. government created the "United States Reports", and at the same time simultaneously numbered the volumes previously published privately as part of a single series and began numbering sequentially from that point. In this  way, "5 U.S. (1 Cranch)" means that it is the 5th overall volume of the "United States Reports" series, but the first that was originally published by William Cranch; four volumes of opinions prior to that were (for example) published by Alexander Dallas (for example, "4 U.S. (4 Dall.)"), and after Cranch's 9 volumes, 12 more were published by Henry Wheaton (e.g., "15 U.S. (2 Wheat.)"). See the Supreme Court of the United States Reporter of Decisions for other edition names. The name of the reporter of decisions has not been used in citations since the U.S. government began  printing the "United States Reports". When a case has been decided, but not yet published in the case reporter, the citation may note the volume but leave blank the page of the case reporter until it is determined. For example, "Golan v. Holder," 565 U.S. 302 (2012) was properly cited as "Golan v. Holder", before publication. In the caption of a Supreme Court case, the first name listed is the name of the petitioning (appealing) party, followed by the party responding (respondent) to the appeal. In most cases, the appealing party was the losing party in the prior court. This  is no longer the practice used in cases in the federal courts of appeal, in which the original alignment of parties from the lower court is preserved. Lower federal courts. United States court of appeals cases are published in the "Federal Reporter" (F., F.2d, or F.3d). United States district court cases and cases from some specialized courts are published in the "Federal Supplement" (F. Supp., F. Supp. 2d, or F. Supp. 3d). Both series are published by Thomson West; they are technically unofficial reporters, but have become widely accepted as the "de facto" "official" reporters of the lower federal courts  because of the absence of a true official reporter. (Of the federal appeals and district courts, only one, the D.C. Circuit, has an official reporter, "United States Court of Appeals Reports", and even that one is rarely used today.) When lower federal court opinions are cited, the citation includes the name of the court. This is placed in the parentheses immediately before the year. Some examples: U.S. circuit and district court cases from 1789 to 1880 were reported in Federal Cases, abbreviated F. Cas. An example of the citation form is: "Wheaton v. Peters", 29 F. Cas. 862 (C.C.E.D. Pa.  1832) (No. 17,486). State courts. State court decisions are published in several places. Many states have their own official state reporters, which publish decisions of one or more of that state's courts. Reporters that publish decisions of a state's highest court are abbreviated the same as the state's name (note: this is the traditional abbreviation, not the postal abbreviation), regardless of what the actual title of the reporter is. Thus, the official reporter of decisions of the California Supreme Court (titled "California Reports") is abbreviated "Cal." (or, for subsequent series, "Cal. 2d," "Cal. 3d", or "Cal. 4th ). In addition to the official reporters, Thomson West publishes several series of regional reporters" that cover several states each. These are the "North Eastern Reporter", "Atlantic Reporter", "South Eastern Reporter", "Southern Reporter", "South Western Reporter", "North Western Reporter", and "Pacific Reporter". California, Illinois, and New York also each have their own line of Thomson West reporters, because of the large volume of cases generated in those states (titled, respectively, "West's California Reporter", "Illinois Decisions", and "West's New York Supplement"). Some smaller states (like South Dakota) have stopped publishing their own official reporters, and instead have certified the appropriate  West regional reporter as their "official" reporter. Here are some examples of how to cite West reporters: Abbreviations for lower courts vary by state, as each state has its own system of trial courts and intermediate appellate courts. When a case appears in both an official reporter and a regional reporter, either citation can be used. Generally, citing to the regional reporter is preferred, since out-of-state attorneys are more likely to have access to these. Many lawyers prefer to include both citations. Some state courts require that parallel citations (in this case, citing to both the official reporter  and an unofficial regional reporter) be used when citing cases from any court in that state's system. Like the United States Supreme Court, some very old state case citations include an abbreviation of the name of either the private publisher or the reporter of decisions, a state-appointed officer who originally collected and published the cases. For example, in "Hall v. Bell", 47 Mass. (6 Met.) 431 (1843), the citation is to volume 47 of "Massachusetts Reports", which, like "United States Reports", was started in the latter half of the 19th century and incorporated into the series a number  of prior editions originally published privately, and began numbering from that point; "6 Met." refers to the 6th volume that had originally been published privately by Theron Metcalf. An example of a case cited to a reporter that has not been subsequently incorporated into an officially published series is "Pierson v. Post", 3 Cai. 175 (N.Y. Sup. Ct. 1804), reported in volume 3 of "Caines' Reports", page 175, named for George Caines, who had been appointed to report New York cases; the case was before the New York Supreme Court of Judicature (now defunct). Most states gave up this practice  in the mid-to-late 19th century, but Delaware persisted until 1920. Some states, notably California and New York, have their own citation systems that differ significantly from the various federal and national standards. In California, the year is placed "between" the names of the parties and the reference to the case reporter; in New York, the year is wrapped in brackets instead of parentheses, while California uses brackets for parenthetical explanations of a case's holding or relevance. Both New York and California styles wrap an entire citation in parentheses when used as a stand-alone sentence to support  the preceding sentence, although New York places the terminating period outside the parentheses, whereas California places it inside. New York wraps just the reporter and page references in parentheses when the citation is used as a clause. Either way, both state styles differ from the national/Bluebook style of simply dropping in the citation as a separate sentence without further adornment. Both systems use less punctuation and spacing in their reporter abbreviations. For example, assuming that it is being placed as a stand-alone sentence, the "Brown" case above would be cited (using the official reporter) to a New York  court as: And, again, as a stand-alone sentence, the famous "Greenman" product liability case would be cited to a California court as: Unpublished decisions. A growing number of court decisions are not published in case reporters. For example, only 7% of the opinions of the California intermediate courts (the Courts of Appeal) are published each year. This is mainly because judges certify only significant decisions for publication, due to the massive number of frivolous appeals flowing through the courts and the importance of avoiding information overload. It is also argued that this is in part because in many states , especially California, the legislature has failed to expand the judiciary to keep up with population growth (for various political and fiscal reasons). To deal with their crushing caseloads, many judges prefer to write shorter-than-normal opinions that dispose of minor issues in the case in a sentence or two. They avoid publishing such abbreviated opinions, however, so as not to risk creating bad precedents. Attorneys have several options in citing "unpublished" decisions: Some court systems—such as the California state court system—forbid attorneys to cite unpublished cases as precedent. Other systems allow citation of unpublished cases only under  specific circumstances. For example, in Kentucky, unpublished cases from that state's courts can only be cited if the case was decided after January 1, 2003, and "there is no published opinion that would adequately address the issue before the court". From 2004 to 2006, federal judges debated whether the Federal Rules of Appellate Procedure (FRAP) should be amended so that unpublished cases in all circuits could be cited as precedent. In 2006, the Supreme Court, over the objection of several hundred judges and lawyers, adopted a new Rule 32.1 of FRAP requiring that federal courts allow citation of unpublished  cases. The rule took effect on January 1, 2007. Vendor-neutral citations. With the rise of the web, many courts placed new cases on websites. Some were published while others never lost their "unpublished" status. The major legal citation systems required cites to the officially published page numbers, in which publishers such as West Publishing claimed a copyright interest. A vendor-neutral citation movement led to provisions being made for citations to web-based cases and other legal materials. A few courts modified their rules to specifically take into account cases "published" on the web. An example of a vendor -neutral citation: Pinpoint citations. In practice, most lawyers go one step farther, once they have developed the correct citation for a case using the rules discussed above. Most court opinions contain holdings on multiple issues, so lawyers need to cite to the page that contains the specific holding they wish to invoke in their own case. Such citations are known as pinpoint citations, "pin cites", or "jump cites". For example, in "Roe v. Wade", the U.S. Supreme Court held that the word "person" as used in the Fourteenth Amendment does not include the unborn. That particular holding appears on page  158 of the volume in which the "Roe" decision was published. A full pin cite to "Roe" for that holding would be as follows: And a parallel cite to all three U.S. Supreme Court reporters, combined with pin cites for all three, would produce: But in its opinions, the Court usually provides a direct pin cite only to the official reporter. The two unofficial reporters, when they reprint the Court's opinions, add on parallel cites to each other, but do not add pin cites. Therefore, a citation to "Roe v. Wade" in a later Supreme Court decision as viewed  on Lexis or Westlaw would appear as follows: Even then, such citations are still quite lengthy, and may look quite mysterious and intimidating to laypersons when they read court opinions. Since the 1980s, there has been an ongoing debate among American judges as to whether they should relegate such lengthy citations to footnotes to improve the readability of their opinions, as strongly urged by Bryan A. Garner, one of the leading authors on legal writing and style. Most judges do relegate "some" citations to footnotes, but jurists such as Justice Stephen Breyer and Judge Richard Posner refuse to use footnotes  in their opinions. Types of citations. There are two types of citations: proprietary and public domain citations. There are many citation guides; the most commonly acknowledged is called "", compiled by the "Columbia Law Review", "Harvard Law Review", "University of Pennsylvania Law Review", and "Yale Law Journal". "Public domain citations" refer to the official reporters, rather than a publication service such as Westlaw, LexisNexis, particular legal journals, or specialization-specific reporters. States with their own unique style for court documents and case opinions also publish their own style guides, which include information on their citation rules.