Susie Salmon is Assistant Director
of Legal Writing and Associate Clinical
Professor of Law at The University of
Arizona, James E. Rogers College of Law.
Before joining Arizona Law, she spent
nine years as a commercial litigator at
large firms in Tucson and Los Angeles.
Citation Apps: Promising but Flawed
Most intriguingly, a Boalt Law 3L recently created a citation-generating tool
called Bestlaw. 6 Bestlaw, a browser extension for Google Chrome, works with
WestlawNext to add a toolbar that,
among other things, generates Bluebook-
compliant case citations. In its first iteration, Bestlaw only works for reported federal cases, but early reviews suggest that
the citation results are wholly accurate. 7
Of course we need to learn legal citation,
and any 2L should be able to recognize a
deficient citation. But once you know the
basics, there’s no shame in relying on shortcuts, so long as you provide the court with
citations that are accurate, brief, and clear.
Ah, Dear Reader. By now, you’ve probably sensed that I
have a bit of a love/hate relationship with legal citation (and, in particular, with our friend The Bluebook). But accurate legal citation is important. Lawyers must provide attribution for their assertions, and their
citations must communicate that attribution both clearly and accurately.
Certainly no judge or law clerk grows fond of a lawyer whose citations
point to the wrong page, the wrong reporter, the wrong volume, the
wrong statute, the wrong rule…
At the same time, adhering to every detail of a particular citation
format1 can be frustrating and sometimes consumes time better spent
on thorough research, thoughtful analysis, and the type of audience-
focused revision that makes your writing as accurate, brief, and clear as
possible. Although most of us have memorized the outlines of a case or
statute citation, often we nonetheless must consult the Bluebook or an-
other manual to verify details like abbreviations or spacing. 2 Word-pro-
cessing programs thwart our efforts to avoid inadvertent superscript. And no
client wants to pay for time spent on the nuances of citation.
Wouldn’t it be nice if there were a reliable and inexpensive shortcut?
And doesn’t it seem like there should be? After all, the Apple tagline
“there’s an app for that” resonates for a reason. The i Tunes store alone
currently includes more than a million apps. The Android store offers
over a million more. A plethora of mobile apps, browser plugins, and
other tech tools exist to help writers working in the sciences to generate
accurate citations that comply with a variety of citation formats, including MLA, APA, Chicago, IIEE, and Harvard styles. Shouldn’t at least
one app be able to generate an accurate, brief, and clear legal citation
that complies with whatever legal-citation style you follow?
Unfortunately, no app, plugin, or online tool currently exists that
reliably creates a perfect legal citation every time. Zotero, RefWorks,
Fear not, though: There is hope! Although all require user
caution, a few tools construct accurate legal citations most of
Most of you are probably familiar with WestlawNext’s
copy-with-reference feature, which allows a user to paste
text into work product, complete with a correctly formatted
citation. Copy with reference seems to allow you to customize your citation format to comply with jurisdiction-specific
rules, but note that if you want to follow Arizona’s appellate
rules, selecting “Arizona” from the drop-down menu will
not get you there; you need to add the paragraph numbers
yourself. 3 Overall, though, every citation the feature generated for me followed Bluebook and ALWD format. 4 Lexis
Advance and Bloomberg Law offer similar options.
CiteGenie, a browser plugin, works in a way very similar
to Westlaw’s “copy with reference” to create accurate citations, complete with pinpoint citations. 5
1. Is it really going to kill anyone if the “th” in
9th Circuit is in superscript? (Editor’s Note:
2. Again, I’m not persuaded that a clear but
should be a problem.
3. See Ariz. R. Civ. App. 13(f) (“Citations of
Arizona case law must be to the volume,
page number and, if available, the paragraph
number, of the official Arizona reporter…
4. Note that Westlaw’s and Lexis’s own
citations, or the citations in the cases they
reprint, do not always comply with Bluebook
(or ALWD) format. Both Westlaw and
Lexis have their own citation systems that
are similar to Bluebook’s, but both use
abbreviations that deviate from those prescribed by Bluebook’s tables. And courts use
their own internal citation systems. If you
want to follow Bluebook format religiously,
you cannot just cut and paste from cases.
7. See, e.g., Ashley Ahlbrand, Research Make-over: Updating Your (Research) Look With
(Browser) Extensions, M.S. J.D.: BLOG
(Oct. 6, 2014), http://ms-jd.org/
blog/article/research-makeover-updating-your-research-look-with-browser-extensions; Carli Spina, Bestlaw:
A New Tool That Aims To Make Westlaw
Better, HARV. L. SCHOOL LIBRARY BLOG
(Oct. 9, 2014), http://etseq.law.harvard.