Lawyers, legal scholars etc. - explain court case citations to me

I’m not a lawyer, but I spend quite a bit of time reading legal history and legal cases. For the most part, it’s pretty easy for me to find what I need, and I generally identify cases by the names of the parties. Because this is generally for my own interest, formal citation isn’t really an issue.

Still, I often find myself confused by the multitude of references for court cases, especially as they wend their way through the system. I know some of the key citation rules, like citing federal cases from the United States Reports (Supreme Court), the Federal Reporter (Circuit Courts), and Federal Supplement (District Courts). But I’m still not sure where some of the different case references come from, and there also doesn’t seem to be any common identifier that tracks a case from one court to the next.

Take this case, for example. It’s Robert Jordan v. City of New London and Keith Harrigan, and is a case about police hiring.

Here’s the citation to the opinion by the District Court in Connecticut:

And here’s the citation from the 2nd Circuit:

So what’s going on with all of the different reference numbers here?

225 F.3d 645 is the Federal Reporter citation, but what are these?

1999 WL 780977

3:97CV1012(PCD)

99-9188.

The middle one is in the format of the case numbers used in the PACER system, but it’s not clear to me what the others reference, nor if there is any relationship between them. When are these numbers allocated, and by whom, and is there any way to trace a case all the way through the system, even from state court systems into the federal system?

If anyone can school me on this, I’d be most appreciate.

I’m a lawyer but not an American one, and citation standards differ hugely between jurisdictions. Yet I think I can be of some help. “1999 WL 780977” is the Westlaw citation - Westlaw is a commercial legal database that assigns its own identifiers to cases. 99-9188, I would think, is an internal case number used by the registry of the deciding court for internal purposes. In most courts, its pretty much a serial number, starting at 1 each year, added to the year in which the case was lodged.

So in essence, the person who made the citation added several redundant citatuons, all referring to the same case, to make it easy for the reader to locate the case, since not all readers have access to the same resources.

1999 WL 780977: This is a Westlaw citation, as noted above. This was a District Court case. Generally, the judge in a District Court decides whether to publish an opinion for any case. The convention is that a judge may choose to publish an opinion, in which case it will be published in the Federal Supplement. Currently, we’re on the third series of the Federal Supplement, so new published opinions get published in the Federal Supplement, third series (or. “F.Supp.3d,”) which is a publication produced by a legal publisher named West. When a judge doesn’t choose to publish an opinion, West may still choose to publish an opinion in F.Supp.3d. Even when the judge doesn’t particularly want to publish an opinion (and even if its marked by the judge as “not for publication”), the opinion is still a public record. So, in those cases, West just collects them all in its database and gives them number citations. 1999 WL 780977 means it’s an opinion (or other document) from 1999 and has serial number 780977. The general convention for citations is to cite to the most widely available reporter. So, if the opinion is reported in F.Supp.3d., lawyers will cite to that. If it’s only available as an unpublished opinion in the Westlaw database, lawyers cite to that.

3:97CV1012(PCD): Yup, as noted, this is a Pacer citation. Handy for finding many documents associated with the case, opinions, orders, motions, etc.

99-9188: This is essentially this particular court’s file number for this case. If you wanted to go to the courthouse and ask the clerk for the documents associated with this case, this is the number you would likely use. But of course, today, you’d basically get most of this information from Pacer and save the trip.

Thanks folks. That all makes sense, although I do wonder why the federal system, at least, couldn’t arrive at an arrangement where there is a single consistent case identifier, set by the federal courts, that follows each case through a journey from District Court to Circuit Court to Appeals Court.

It’s a good idea but it suffers from at least two problems: you have to undo all the standards that came before it and which work well enough for the people using them now and you have to get everyone on board with a new standard that they all like better than the current system. There is even an XKCD for this!

No. 3:97CV1012(PCD) You may (or may not) find it interesting that the “PCD” usually refers to the initials of the District Court judge assigned. If it’s assigned to a Magistrate Judge, two initials are used. 97 is the year the Complaint was filed CV means it’s a civil case. It’s probably the 1012th civil case filed that year in that district.

Been practicing for over a decade, including time as a federal clerk (!), and never noticed the two initials vs. three initials thing. Thanks.

Just get yourself a blue book, and everything will be simple and crystal clear! :smiley:

Well, unless you want to use the maroon book…

My personal observation is that I historically declined to be too concerned with specific forms of case (or other) citations. Instead, my position was to include sufficient information that a, interested party could identify the source without excessive effort. These days, there is more expectation of standardization due to the reliance of scanning tools.

I don’t think the outcome of any case I was ever involved in depended on anyone’s citation method. And thankfully, my current practice requires little or no citation.

Now remind me, does the period go inside the paren or out? :rolleyes:

In Canada, the question used to be “Round brackets or square brackets?”

And the answer to that question, at least in England (which makes me think the same logic applies also in Canada), is:

Square brackets are used for year numbers if the journal or reporter in question denotes individual volumes in the series by year number. So, for instance, the tort case of Donoghue v Stevenson (note the missing period after the v, as per English usage) is reported in the Appeal Cases (AC) reports as [1932] AC 562 - page 562 in the 1932 volume of that series.

Round brackets, on the other hand, are used if the journal or reporter in question uses a different numbering scheme for individual volumes, but the year number is also given in round brackets. So, for instance, an article in the Maastricht Journal of European and Comparative Law, commonly abbreviated as MJ, might be cited as (2014) 21 MJ 89, meaning it starts on page 89 of volume 21 of that journal, which is the 2014 volume.

Legal systems which are still based on the English Common Law - and some US jurisprudence still uses part of it - may have to refer to even older precedents such as Bushel’s Case (1670) 124 E.R. 1006. Here the legal book was put together much later and summarised cases up to 1865. Subsequent ones were referenced by the Incorporated Council of Law Reporting for England and Wales and referenced in an L.R. series.

As with so many things, legal citations to case law is a confusing mish-mash of historical systems. (And, also like so many things, there are numerous oddities, inconsistencies, and exceptions, so this is just a general discussion).

Legal decisions were, and still are though they are less commonly used in the internet age, printed in series of bound volumes, some put out by private companies, some put out as official government publications.

For instance, the West Publishing Company (the biggie in case law publishing) originally published federal Court of Appeals decisions in the Federal Reporter. A decision would be referred to by the volume number then “Fed.” indicating the Federal Reporter, and then the page number the decision started on, for instance 220 Fed. 405. To find that decision, you would pull volume 220 of the Federal Reporter off the shelf, and open to page 405 to find the case. After the Federal Reporter reached an unwieldy number of volumes, West started issuing the Federal Reporter, Second Series, and later Third Series, abbreviated as F.2d and F.3d. For instance, the Jordan v. City of New London case you cite, 225 F.3d 645, can be found starting on page 645 of volume 225 of the Federal Reporter, 3rd Series.

Often the same cases will be published in multiple reporters, often an official government reporter and a private reporter. For instance, U.S. Supreme Court decisions are published in United States Reports (abbreviated U.S.), an official publication issued by the federal GPO, as well as West’s Supreme Court Reporter (abbreviated S.Ct.), which is published more quickly than the official government reporter, and also has editorial enhancements such as headnotes, which make legal research easier using that format.

States have a mix of similar reporting systems, with West having a National Reporter System of books that cover all decisions “officially” issued for publication, with many states having their own reporters (though some use the West reporters as their official case books). In most states, all decisions of the states highest appeals case, and most or all of the decisions of the intermediate appellate courts, are officially reported, and some decisions at the trial court level are. The West reporters are regional, with titles like “Northeast Reporter,” or “Southern Reporter,” though because of their volume of case law, California and New York have their own “Supplement” series of reporters, which include lower court decisions from those states, with the highest court decisions reported both in the supplement and the regional reporter.

Currently, most everything is online, but officially reported cases are still referenced by the volume and page numbers in the official books.

This brings to “unreported” cases, meaning cases not published in the official case books. Because there are many more decisions than can be reasonably published in bound volumes, particularly at the lower court level, many cases are published in electronic form only. There are two, large commercial case reporting databases, Westlaw (from West Publishing) and Lexis, as well as some smaller services. Westlaw takes all materials published on their service dating from a given year, and gives them a citation number starting with the year, then “WL” and then a serial number based on all of the documents added to the service for that year. For instance, 1999 WL 780977 is the 780977th document from 1999 added to Westlaw. Lexis lists documents by year and category, such as 1999 U.S. Dist. Lexis 2345, meaning it is the 2345th U.S. District Court decision from 1999 added to the database.

In addition, many states have online databases of their opinions. For instance, the New York Reporter of Decision (an official of the court system) indexes decisions and posts them online under a New York Slip Opinion number (N.Y. Slip Op.), including official decisions from the appellate courts (and some officially reported lower court decisions), as well as .pdf scans of many trial court opinions that have not been officially reported.

Finally, and this does not really involve the citation of legal decisions, each court will give each case or appeal before it a unique identifying number, often known as a Case Number or an Index Number. Federal District Courts typically give cases numbers in the form of “97-CV-1012-PCD,” where 97 means the case was filed in 1997, CV mean it is a civil case (as opposed to CR for criminal, and some other codes), 1012 means it is the 1012th civil case filed that year, and PCD are the initials of the assigned judge (the 3: is a code used in some districts for what courthouse or division the case is in). Federal appeals courts usually give appeal numbers like “99-9188,” which means that the case was filed in 1999 and given number 9188.

Services like Westlaw have a function that (sometimes imperfectly) tracks the history of decisions issued in a case, including appeals (sometimes multiple appeals), remands, and other decisions issued. And, typically, where an appeal reviews an officially-reported lower court decision, it will note the citation of that decision. Otherwise, if a reported appeal decision lists the case number of the lower court case, often you can go to the docket of that case in the lower court (particularly where cases are under a publicly available electronic filing system) and find the decision that is being reviewed.