Parallel Citations- Past and Present

• Publication year: 2001
• Pages: 25
• Citation: Vol. 30 No. 1 Pg. 25

30 Colo.Law. 1 Colorado Lawyer 2001.

2001, January, Pg. 25. Parallel Citations- Past and Present

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25

Vol. 30, No. 1, Pg. 1

The Colorado Lawyer
January 2001
Vol. 30, No. 1 [Page 25]

Departments
The Scrivener: Modern Legal Writing
Parallel Citations - Past and Present
by K. K. DuVivier
C 2000 K.K. DuVivier

If you graduated from law school before 1991, you may be including parallel citations in all of your legal writing Parallel citations are citations to two or more alternative sources for finding the same authority. The practice of citing more than one source has been around for a long time In the mid- to late- 1800s, many state governments began publishing the state court decisions in official state reporters.1 From twenty to fifty years later, West Publishing Company began reporting these same cases in its national system, thus creating an alternative source for finding those cases.2

Citation to multiple sources became a courtesy, and sometimes a necessity. While the attorney who was preparing a brief might be using the West version of a case, the judges and law clerks reading that brief might have access only to the official state reporter. The burden was placed on the writer to find the citation to the parallel page of the alternative version of a reporter so that the readers could easily verify the information cited

By quiet decree, the fifteenth edition of the Bluebook3 changed all of this. The convention of using parallel citations was dropped in every instance except for "state court cases in documents submitted to courts of the state that originally decided them."4 Parallel citations were no longer required in legal memoranda or law reviews.5 Furthermore, the fifteenth edition required writers to use only the West version when a single source was listed. This new rule seemed to undermine the value of official citations that traditionally came before the unofficial West versions and suggested a preference for the official source issued by the state governments.

Many factions rebelled against the Bluebook's edict. Some suggested it was inappropriate to favor one particular vendor over another and contributed to the start of a movement toward "vendor neutral" or "medium neutral" citations. Some courts, such as the Colorado Court of Appeals, simply froze their citation conventions back at the fourteenth edition of the Bluebook, which required...