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Supreme Court Adopts Universal Citation Format

Back in June, the Supreme Court of North Carolina sought feedback on a potential change to the citation format for North Carolina appellate court opinions.  This week, the Court has officially made plans for the universal citation format to go into effect.  The purpose of the change is to present “an immediate, permanent, and medium-neutral” citation the moment an opinion is issued.

Under the new format, each opinion will contain a unique opinion number and paragraph numbers that will be native to the text.  The official opinions will still be in the North Carolina reporters.  Proper case citations will therefore include the following:  the case name, a citation to the North Carolina reporter, the new universal citation, and (as appropriate) a pinpoint citation to a particular paragraph.  For example:

State v. Smith, 257 N.C. App. 43, 2021-NCCOA-23, ¶ 8

The change is effective at the beginning of 2021, which will give the courts, the clerks, and practitioners time to work out the details–and come to grips with the change.

The Supreme Court’s administrative order announcing the change can be found here.  Let us know your thoughts, and what questions you have, in the comments below.

–Kip Nelson

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3 Responses to "Supreme Court Adopts Universal Citation Format"

  • Ed Walters
    December 5, 2019 - 2:19 pm Reply

    If the Court is interested in retrofitting pre-2021 opinions with media-neutral citations, our team at @Fastcase can help them do that!

  • Mike Harrell
    December 12, 2019 - 10:13 am Reply

    I’m assuming if we are citing to pre-2021 cases that we’ll still cite to both the official reporter and then the S.E./S.E.2d reporter? Or just the official reporter? The administrative order is unclear.

    • Kip Nelson
      December 12, 2019 - 10:52 am Reply

      That’s a great question, and I don’t think we know the answer yet. If uniform citations are provided for all pre-2021 cases as well, then all cases will probably be cited in the same way. This issue will likely be one that is discussed and addressed in the next year.

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