Byline: Bill Cresenzo
North Carolina Reports, the official publication of the North Carolina Supreme Court opinions, has been around since 1778--a time when the musical Hamilton would have been a jaunty summary of breaking news. But its book-and-page number method for citing previous cases has remained almost unchanged since then, despite the fact that the old ways of doing things are increasingly ill-fit for purpose in a digital age.
So in an effort to drag its methods for case citations into the modern era, the North Carolina Supreme Court has announced that it will soon be adopting a new format for citations to help make opinions more accessible to attorneys and the public.
Beginning in January 2021, the citation for each opinion from the state's appellate courts will include a year and universal opinion number, along with paragraph numbers to use when citing a quotation or specific holding, said Justice Anita Earls, who helped spearhead the change. These numbers will be native to the text of the opinion, allowing them to appear across a variety of mediums.
The traditional book-and-page numbers will still appear alongside the new numbers, and the hardcopy North Carolina Reports and the North Carolina Court of Appeals Reports will remain the official record of the courts.
So under the new format, a Supreme Court case citation would read as State v. Smith, 375 N.C. 152, 2020-NCSC-4516. A Court of Appeals citation would read as State v. Smith, 255 App 43, 2020NCCOA-18823.
Those musty hardcopy court reporters that lawyers will remember so well from law school still make an elegant decoration for any law office, but most people today do their actual legal research online, where a crucial section of an opinion might not always appear on the same page number as in the hardcopy reports. That makes it difficult to uniformly refer to cases, said Sharon Gladwell, communications director for the North Carolina Administrative Office of the Courts.
Moreover, the paragraph numbers will allow readers to more quickly and accurately identify source material in both electronic and hardcopy formats. The North Carolina Business Court already uses universal citations.
"This change was needed because the book-and-page citations currently in use are ill-suited to electronic sources of legal opinions," Earls said. "With increasing use of multiple...