Legal researchers spend a lot of time tracking down case citations, parallel citations and pinpoint cites. This started even before West Publishing Co. began publishing case reporters in the late 19th century. The advent of computerized legal research has made this process easier in some respects, but the Internet has complicated it in others.

A myriad of legal material is now available to everyone on the World Wide Web, but how should it be cited? For example, many courts post an opinion on the Internet as each case is decided but without a citation. In most situations, researchers must then track down a traditional citation to a case reported in this manner to be able to cite to it in a legal document.

Proponents of a universal system of citation believe that a uniform, vendor- and medium-neutral legal citation system, one in which every cite is uniform no matter who publishes it or whether it is in a book or on a computer, would solve the citation problem. Each court would issue citations to cases, as they were decided, numbered sequentially in chronological order with each paragraph numbered also. Citations to statutes and administrative codes would be issued as they were enacted and would be written in a format used by all states. Citations to primary sources would be uniform no matter what medium was used.

No Easy Task
Universal adoption of such a system is no easy task because it involves all branches of government, both state and federal, as well as cooperation from legal publishers and vendors. Behind the push for universal citations are several national groups. In 1992, the U.S. Judicial Conference created a citation system for cases on electronic bulletin boards. However, that system is currently being used by only one appellate court, the U.S. Court of Appeals for the Sixth Circuit.

The American Bar Association endorsed an universal citation system in 1996 and presently its Standing Committee on Technology and Information Services is working on implementation of the system.

Despite these efforts, currently less than a dozen states have adopted universal citation. For a list of the states that have adopted and those that are considering adoption see the ABA's website at www.abanet.org/citation.

The American Association of Law Libraries has been committed to an universal citation system since 1994. Marcia Koslov, State Law Librarian of Wisconsin, whose state has adopted universal citation, is chair of the Universal Citation Committee of the AALL. AALL's effort has most recently resulted in the publication of the Universal Citation Guide. Published in May 1999, the guide outlines AALL's proposal to establish a vendor- and medium-neutral citation system, which they hope will be adopted by all states.

AALL's Universal Case Citation system is modeled after Wisconsin's system and only differs from the ABA's with respect to the court abbreviation designation. The ABA uses old state postal abbreviations and the AALL uses the new state postal abbreviations. The AALL has numbered each paragraph of the Universal Citation Guide, emphasizing the theory that numbering of paragraphs makes legal research easier because each paragraph is easily identified.

In Pennsylvania
Although Pennsylvania has not officially adopted a universal system of citation, key members of the legal profession are involved in studying what should be done, and some action has been taken. A symposium sponsored by Villanova University, the Pennsylvania Futures Commission on Justice in the 21st Century and PaLAWnet was held in Philadelphia in June 1998. Attended by lawyers, librarians, state officials and publishers, this meeting started the move toward a statewide agenda on universal citation.

The first major step toward adoption of the Universal System of Citation in Pennsylvania was taken by the Pennsylvania Superior Court. In January 1999, the Superior Court began issuing opinions containing a universal citation. (i.e.: Jones v. Smith, 1999 Pa Super 1.)

However, this citation is used only until the case receives an Atlantic 2d citation. The universal cite is used in place of a docket number or LEXIS or Westlaw cite. Additionally, each paragraph of an opinion is numbered for pinpoint citations. According to Judge Joseph A. Del Sole of the Pennsylvania Superior Court, the court's adoption of the universal citation came about in response to a number of requests. Once the Superior Court started making its opinions available on the Internet, users wanted an easy way to cite to them.

The decision to use the universal cites only until the Atlantic 2d is published was made because the court did not want a dual citation system. The Superior Court wanted to make access to opinions easy for everyone, not just lawyers, but at the same time did not want to jeopardize traditional research by burdening attorneys. Since the Superior Court had already eliminated the state published official citations, it did not want to return to parallel citations. According to Judge Del Sole, the Court has not received any complaints to date, only compliments.

Other Pa. Courts
What about the other Pennsylvania courts?

Because Pennsylvania does not have a unified court system, each court must individually decide whether to adopt a universal citation system. Charles Johns, prothonotary of the Pennsylvania Supreme Court, knows of no immediate plans to adopt such a system. According to the executive administrator of the Pennsylvania Commonwealth Court, G. Ronald Darlington, the Commonwealth Court has no plans to adopt universal citation and is not even discussing it.

On the legislative and administrative levels in Pennsylvania, adoption of a universal citation system is no further along. Clancy Myer, Pennsylvania House of Representatives parliamentarian claims that there is nothing in the works right now in the House. And in the Senate, Steve MacNett, general counsel for the Pennsylvania Senate Majority knows of no action concerning universal citation. Gary Hoffman, director of the Pennsylvania Code and Bulletin, says that his office is studying universal citation, but that it is presently sticking with the current system, which is mandated by the Pennsylvania Joint Committee on Documents.

Presently, the universal citation system remains far from universal in Pennsylvania and the nation. Advocates of the system will need to convince legal publishers and those unwilling to break from tradition, that universal citation is the best system for everyone befoore it is adopted universally.