Case Citation - United States - State Courts

State Courts

State court decisions are published in several places. Many states have their own official state reporters, which publish decisions of one or more of that state's courts. Reporters that publish decisions of a state's highest court are abbreviated the same as the state's name (note: this is the traditional abbreviation, not the postal abbreviation), regardless of what the actual title of the reporter is. Thus, the official reporter of decisions of the California Supreme Court (titled California Reports) is abbreviated "Cal." (or, for subsequent series, "Cal. 2d," "Cal. 3d" or "Cal. 4th").

• Palsgraf v. Long Island R.R. Co., 248 N.Y. 339 (1928) - a case in the New York Court of Appeals, reported in New York Reports. Note that the New York Court of Appeals is actually the highest court in New York.

• Green v. Chi. Tribune Co., 286 Ill. App. 3d 1 (App. Ct. 1996) - a case in the Illinois Appellate Court, reported in Illinois Appellate Court Reports. Note that, in contrast to New York, the Illinois Appellate Court is only the intermediate court of appeals in Illinois; decisions of the Illinois Supreme Court are reported in Illinois Reports, abbreviated "Ill." (or "Ill. 2d").

In addition to the official reporters, Thomson West publishes several series of "regional reporters" which cover several states each. These are the North Eastern Reporter, Atlantic Reporter, South Eastern Reporter, Southern Reporter, South Western Reporter, North Western Reporter, and Pacific Reporter. California, Illinois, and New York also each have their own line of Thomson West reporters, because of the large volume of cases generated in those states (titled, respectively, West's California Reporter, Illinois Decisions, and West's New York Supplement). Some smaller states (like South Dakota) have stopped publishing their own official reporters, and instead have certified the appropriate West regional reporter as their "official" reporter.

Here are some examples of how to cite West reporters:

• Jackson v. Commonwealth, 583 S.E.2d 780 (Va. Ct. App. 2003) - a case in the Virginia Court of Appeals (an intermediate appellate court) published in the South Eastern Reporter
• Foxworth v. Maddox, 137 So. 161 (Fla. 1931) - a case in the Florida Supreme Court published in the Southern Reporter
• People v. Brown, 282 N.Y.S.2d 497 (1967) - a case in the New York Court of Appeals (New York's highest court) published in the New York Supplement. The case also appears in West's regional reporter: People v. Brown, 229 N.E.2d 192 (N.Y. 1967).

Abbreviations for lower courts vary by state, as each state has its own system of trial courts and intermediate appellate courts.

When a case appears in both an official reporter and a regional reporter, either citation can be used. Generally, citing to the regional reporter is preferred, since out-of-state attorneys are more likely to have access to these. Many lawyers prefer to include both citations. Some state courts require that parallel citations (in this case, citing to both the official reporter and an unofficial regional reporter) be used when citing cases from any court in that state's system.

Some states, notably California and New York, have their own citation systems that differ significantly from the various federal and national standards. Citations in California style put the year between the names of the parties and the reference to the case reporter. Citations in New York style wrap the year in brackets instead of parentheses. Both New York and California wrap an entire citation in parentheses when it is used as a stand-alone sentence. New York puts the terminating period outside the parentheses, but California puts it inside. New York wraps just the reporter and page references in parentheses when the citation is used as a clause.

Either way, both state styles differ from the national/Bluebook style of simply dropping in the citation as a separate sentence without further adornment. Both systems use less punctuation and spacing in their reporter abbreviations.

For example, assuming that it is being placed as a stand-alone sentence, the Brown case above would be cited (using the official reporter) to a New York court as:

• (People v Brown, 20 NY2d 238 ).

And, again, as a stand-alone sentence, the famous Greenman product liability case would be cited to a California court as:

• (Greenman v. Yuba Power Products, Inc. (1963) 59 Cal.2d 57.)

Like the United States Supreme Court, some very old state case citations include an abbreviation of the name of either the private publisher or the reporter of decisions, a state-appointed officer who originally collected and published the cases. For example, in Hall v. Bell, 47 Mass. (6 Met.) 431 (1843), the citation is to volume 47 of Massachusetts Reports, which, like United States Reports, was started in the latter half of the 19th century and incorporated a number of prior editions originally published privately into the series, and began numbering from that point; "6 Met." refers to the 6th volume that had originally been published privately by Theron Metcalf. An example of a case cited to a reporter that has not been subsequently incorporated into an officially-published series is Pierson v. Post, 3 Cai. 175 (N.Y. Sup. Ct. 1804), reported in volume 3 of Caines' Reports, page 175, named for George Caines, who had been appointed to report New York cases; the case was before the New York Supreme Court of Judicature (now defunct). Most states gave up this practice in the mid- to late-19th century, but Delaware persisted until 1920.