Information Connection, 0419 WYBJ, Vol. 42 No. 3. 46

• Author: Debora Person, Associate Law Librarian University of Wyoming Law Library
• Position: Vol. 42 3 Pg. 46

Information Connection

Vol. 42 No. 3 Pg. 46

Wyoming Bar Journal

April, 2019

The

Problem of Citing Wyoming Regulations

Debora

Person, Associate Law Librarian University of Wyoming Law

Library

Today I

advocate for a standard citation format for Wyoming

regulations, a citation uniform across all

platforms—one that may be entered into the search box

of an electronic resource rather than using the table of

contents for Wyoming’s administrative code or

performing a keyword search to identify a browse list of

possible regulations.

My

interest in citing regulations began a few years ago. As I

scanned the decisions of the Wyoming Supreme Court that come

out through Wyoming Attorneys-L listserv,¹ I noticed the

Clements case in which the court stated,

“Workers’ Safety and Compensation Division

exceeded its statutory authority when it adopted a rule that

additional temporary total disability (TTD) benefits beyond

24 months could not exceed 12 months

…”² The decision does not provide a

complete citation to the regulation but references

“Chapter 7, Section 2(b) of the Division

rules.”³ Interested in the case as an example

of court actions on regulations and with the hope of a

Shepardizing teachable moment, I followed up. This regulation

never was fagged in any database. Lexis and Casemaker do not

citate state regulations. KeyCite in Westlaw does, but it

didn’t catch this reference.

A look

at the citing references Westlaw did catch shows

Dorman citing the regulation as “Wyoming

Workers' Compensation Div., Rules, Regulations and Fee

Schedules, Ch. 7 § 2(b)(i),”⁴ and Picozzi

citing the regulation as “Rules, Regulations and Fee

Schedules of the Wyoming Workers' Safety and Compensation

Division, ch. 7, § 2(b)(i)-(ii).”^[5] Such

references are typical of other cases that cite Wyoming

regulations, and they are sufficient to locate the correct

regulation but not in an efficient manner, and they certainly

are not standardized.

Why is

this so challenging? Let’s review how this regulation

is identified in our legal resources. (see chart on next

page)

There

is some lack of consistency. Our state regulations

compilation is referred to as Weil’s Code of

Wyoming Rules ( WCWR), Code of Wyoming Rules,

Wyoming Code of Rules, and Wyoming Rules and

Regulations or Wyoming Administrative Code (WY

ADC). On the positive side, all of these electronic

systems now identify the Department of Workforce Services as

053, Workers’ Compensation Division as 0021...