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Citing Sources or Mitigating Plagiarism: Teaching Law Students the Proper Use of Authority Attribution in the Digital Age

Published online by Cambridge University Press:  28 February 2019

DeCarlous Y. Spearman
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Extract

Learning the rules of legal citation is a challenge for new and seasoned legal researchers alike. Good instruction and practice are required to master these rules. Think about the first sport you learned to play. Did you master all the rules the first time you played the game? Do most people even read a rule book when learning to play a new sport? Initially, it is a challenge for any player learning the game to follow all of the rules correctly. Generally, only coaches study the rule book. The rules of the game are very important so coaches and players know what is and is not permitted “on the field.”

Most rules are disseminated orally and learned through practice. Law professors who teach legal research or supervise legal writing are the coaches in the game of legal citation; they must disseminate the rules to their students. The professors have a duty to stimulate a student's mastery of legal citation rules to meet the proficiency required of legal writing in the profession. Law students who do not master the rules of legal citation are more likely to plagiarize.

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Articles
Information
International Journal of Legal Information , Volume 42 , Issue 2 , Summer 2014 , pp. 177 - 219
Copyright
Copyright © 2014 by the International Association of Law Libraries. 

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References

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69 Chicago survey of law firm issues with new student's arguments judges often stops presentations and request the authority. First year students participating in the law review write-on process are eager to learn citing in law review articles, footnotes, or endnotes. Also, a 1994 survey of Texas appellate judges and clerks concluded that “'citation form [was] so wrong as to be distracting'” and in a 2003 survey the judges polled found citation mistakes to be common problems in legal writing. Wayne Schiess, Ethical Legal Writing, 21 Rev. Litig. 527, 536 (2002) (quoting Pamela Stanton Baron & Douglas W. Alexander, Briefing to the Texas Courts of Appeals and the Texas Supreme Court—Avoiding Common Mistakes, Fourth Annual Conference on Techniques for Handling Civil Appeals in State and Federal Court 15 (Univ. Tex. Sch. Law 1994)); Ian Gallacher, Cite Unseen: How Neutral Citation and America's Law Schools Can Cure Our Strange Devotion to Bibliographical Orthodoxy and the Constriction of Open and Equal Access to the Law, College of Law Faculty Scholarship (2007), available at http://surface.syr.edu/cgi/viewcontent.cgi?article=1001&context=lawpub. In particular, they determined the absence of citation error more important than the absence of punctuation or spelling errors. Gallacher, 2 n.9 (quoting Susan H. Kosse & David ButleRitchie, How Judges, Practitioners, and Legal Writers Teachers Assess the Writing Skills of New Law Graduates: A Comparative Study, 53 J. Legal Educ. 80, 90 (2003)).Google Scholar

70 E.g, Kapco Mfg. Co. v. C & O Enters., Inc., 886 F.2d 1485, 1496 (7th Cir. 1989) (sanctioning an attorney whose “briefs misrepresented propositions of law in legal treatises and misrepresented facts”); Wallace Computers Servs., Inc. v. David Noyes & Co., No. 93 C 6005, 1994 WL 75201, at *1 (N.D. Ill. Mar. 9, 1994) (trial court chastised defense counsel for repeatedly citing authority “in an inappropriate, out of context manner”); Federated Mut. Ins. Co. v. Anderson, 991 P.2d 915, 922 (Mont. 1999) (dismissing appeal for, among other reasons, inaccurate citations to authority); Carrier v. Salt Lake Cnty., 104 P.3d 1208, 1213-14 (Utah 2004) (discussing whether to strike pleadings as a result of inaccurate record citations and inadequate citation of legal authority).Google Scholar

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75 Vice President Joe Biden presents the best example of how plagiarism can haunt one for a lifetime. In 1965, Biden committed his first act of plagiarism as a first year law student at Syracuse University College of Law. E. J. Dionne Jr., Biden Admits Plagiarism in School But Says It Was Not ‘Malevolent,' N.Y. TIMES, Sept. 18, 1987, available at http://www.nytimes.com/1987/09/18/us/biden-admits-plagiarism-in-school-but-says-it-was-not-malevolent.html.Biden plagiarized part of a paper he wrote in his legal methods course from a law review article entitled “Tortious Acts as a Basis for Jurisdiction in Products Liability Cases” that was published in the Fordham Law Review. Id. His law school record indicated that “five pages of Biden's 15-page paper were copied without quotation or attribution.” Jack Shafer, What Kind of Plagiarist Is Joe Biden? The Unusually Creepy Kind, Slate (Aug. 26, 2008), http://www.slate.com/articles/news_and_politics/press_box/2008/08/what_kind_of_plagiarist_isjoe_biden.html. Although Biden's first plagiarism charge eventually appeared to be just a bad memory, it returned to haunt him in his 1987 and 2008 presidential campaigns when a second charge of plagiarism surfaced. This time Biden was accused of taking major parts of a speech by British politician Neil Kinnock and incorporating it into his campaign speech. Id. Upon disclosure, this action became the downfall of his campaign. Although many may not have been aware of either incident, the information resurfaced during his 2008 presidential campaign and continued to haunt him.Google Scholar

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124 Gerhardt, supra note 76.Google Scholar

125 “Mosaic or ‘patchwork’ plagiarism is when a writer does not directly copy another's work, but instead changes a few words or slightly reorganizes some sentences. Though mosaic plagiarism is not a word-for-word account of someone else's work, it uses many of the ideas and concepts in an obvious way.” Leslie Nierste, Three Kinds of Plagiarism, eHow, http://www.ehow.com/info_7986111_three-kinds-plagiarism.html#channel=f20428e4bc76414&origin=http%3A%2F%2Fwww.ehow.com (last visited Oct. 15, 2013); see also Definitions/Plagiarism, Academic Integrity, http://webs.purduecal.edu/integrity/dishonesty/definitions-plagiarism/; What Constitutes Plagiarism? Harvard Guide to Using Sources. http://isites.harvard.edu/icb/icb.do?keyword=k70847&pageid=icb.page342054; Bowdoin Office of the Dean of Student Affairs, Common Types of Plagiarism, http://www.bowdoin.edu/studentaffairs/ academichonesty/common-types.shtml.Google Scholar

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134 Id.Google Scholar

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136 Id.Google Scholar

137 Id.Google Scholar

138 Id.Google Scholar

139 Id.Google Scholar

140 Id. at 40.Google Scholar

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151 SafeAssign™ Plagiarism-Checking Service, www.lexisnexis.com/lawschool (last visited June 28, 2014).Google Scholar

152 SafeAssign™ Plagiarism-Checking Service, www.lexisnexis.com/lawschool (last visited June 28, 2014).Google Scholar

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157 Young attorneys entering law firms are expected to draft legal documents and are often directed to formbooks to retrieve sample documents they can edit to fit the facts of their client's case. Practicing attorneys often incorporate the use of formbooks in their legal drafting. In the practice of law, this text is freely borrowed and recycled without attribution. Gerhardt, supra note 76.Google Scholar

158 See Bibbero Sys. Inc. v. Colwell Sys., Inc., 893 F.2d 1104, 1106-07 (9th Cir. 1990); John H. Harland Co. v. Clarke Checks, Inc., 711 F.2d 966, 971 (11th Cir. 1983). The blank forms rule, first articulated in Baker v. Selden, 101 U.S. 99 (1879), is codified at 37 C.F.R. § 202.1(c) (1982)Google Scholar

159 37 C.F.R. § 202.1(c).Google Scholar

160 See Bibbero, 893 F.2d at 1106.Google Scholar

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162 Id.Google Scholar

163 Tracy L. McGaugh & Christine Hurt, Interactive Citation Workbook for The Bluebook: A Uniform System of Citation (Lexis 2009).Google Scholar

164 Id.Google Scholar

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166 Gerhardt, supra note 76.Google Scholar

167 University of Hawaii at Mānoa William S. Richardson School of Law, Policy on Plagiarism, at 10.Google Scholar

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170 Martin, Brian, Plagiarism: A Misplaced Emphasis, 3 J. Info. Ethics 36-47 (1994), available at http://www.uow.edu.au/~bmartin/pubs/94jie.html. When a citation is used after paraphrased work, it alerts the reader that the original author's information has been restated and gives credit to the original author. This removes any potential charge of plagiarism.Google Scholar

171 University of Hawaii at Mānoa William S. Richardson School of Law, Policy on Plagiarism, at 10. Under an exception to this rule, some legal scholars omit a citation when the idea can be found in five or more independent sources.Google Scholar

172 Bluebook R. 10, at 87-109.Google Scholar

173 Id. R. 1.2, at 54-56. When a signal is incorporated, it should be accompanied by a parenthetical describing the relevance of the source. The citation and signal combination give credence to the purpose for citing the authority.Google Scholar

174 Johnson, Tom, How to Write an Essay: 10 Easy Steps 59, Aug. 2004, available at http://www1.aucegypt.edu/academic/writers/.Google Scholar

175 Bluebook R. 10.6.2, at 100.Google Scholar

176 Lattman, Peter, Footnotes & the Law, Wall St. J. L. Blog (June 15, 2006, 3:19 PM), http://blogs.wsj.com/law/2006/06/15/footnotes-the-law/.Google Scholar

177 Dickerson, Darby, Footnoting Law Review Competition Papers, 30 Stetson L. rev. 477, 478 (2000).Google Scholar

178 Bales, Richard A., Footnotes, 68 Bench & Bar Kentucky 41 (2004). Citations should not be the transition for a sentence. Test the substance of the citation.Google Scholar

179 Id.Google Scholar

180 Seligmann, Terry Jean & Seymour, Thomas H., Choosing and Using Legal Authority: The Top Ten Tips, 6 Persp. 1 (1997), reprinted in The Best of Perspectives 73 (2001).Google Scholar

181 Plagiarism.org, http://www.plagiarism.org/citing-sources/cite-sources/.Google Scholar

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183 Id.Google Scholar

184 Id.Google Scholar

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186 Rodell, Fred, Goodbye to Law Reviews, 23 Va. L. Rev. 38 (1937); Fred Rodell, Comment, Goodbye to Law Reviews—Revisited, 48 Va. L. Rev. 279 (1962); see also Jack M. Balkin, The Footnote, 1989, Faculty Scholarship Series, Paper 287 (some law students, lawyers, and legal academics believe, “footnotes are the real measure of worth in legal writing”), available at http://digitalcoomons.law.yale.edu/fss_papers/287. However, students should be aware that overusing footnotes or using textual footnotes can be distracting. Bales, supra note 178. Cramming six footnotes into one sentence may increase an academic author's footnote and tenure chances, but it is unlikely to enhance a reader's understanding of the material. Bales, supra note 178. Noel Coward, once said: “Having to read a footnote resembles having to go downstairs to answer the door while in the midst of making love.” G.W. Bowersock, The Art of the Footnote, 53 American Scholar 54, 54 (1984).Google Scholar

187 Bales, supra note 178.Google Scholar

188 Balkin, J. M., The Footnote – Part 1, http://www.yale.edu/lawweb/jbalkin/articles/footl.htm.Google Scholar

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190 Id.Google Scholar

191 Gerhardt, supra note 76.Google Scholar

192 Schiess, supra note 69, at 541; Westinghouse Elec. Corp. v. NLRB, 809 F.2d 419, 425 (7th Cir. 1987).Google Scholar

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194 Id.; Gerhardt, supra note 76.Google Scholar

195 Van Winkle v. Owens-Corning Fiberglas Corp., 683 N.E.2d 985, 989-90 (Ill. App. Ct. 1997).Google Scholar

196 Id.Google Scholar

197 Schiess, supra note 69, at 536. Pinpoint citation is also called a jump citation, dictum page, or pincite. Black's Law Dictionary 278 (9th ed. 2009).Google Scholar

198 Dickerson, Darby, Citation Frustrations—And Solutions, 30 Stetson L. Rev. 477, 507 (2000).Google Scholar

199 Association of Legal Writing Directors & Darby Dickerson, ALWD Citation Manual: A Professional System of Citation 36 (Aspen Publishers 4th ed., 2010).Google Scholar

200 Schiess, supra note 69, at 536.Google Scholar

201 Gerhardt, supra note 76, at 16. When you fail to refer readers to specific pages where the referenced material appears, readers become frustrated. Scheiss, supra note 69, at 537. Pinpoints are valuable to anyone who reads and checks legal authority because without pinpoints, the checker's job is much more complicated. Id.Google Scholar

202 Schiess, supra note 69, at 537.Google Scholar

203 Bryan A. Garner, The Elements of Legal Style 86 (1991).CrossRefGoogle Scholar

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210 Id.Google Scholar

211 Id. at 19.Google Scholar

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213 Malmud, Joan, Adding Method and Alleviating Madness: A Process for Teaching Citation, 12 Persp. 117 (2004).Google Scholar

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215 Shepard's provides an 800 number on each of their titles. How to Shepardize: Your Guide to Legal Research Using Shepard's Citations, https://www.lexisnexis.com/shepardscitations/printsupport/shepardize_print.pdf.Google Scholar

216 Joel Fishman & Dittakavi Rao, Navigating Legal Research & Technology: Quick Reference Guide to the 1,500 Most Common Questions about Traditional and Online Legal Research 45 (2010).Google Scholar

217 Nancy J. Kippenhan, Assistant Professor of Law Liberty University School of Law, www.liberty.edu/academics/business/index.cfm?PID=26798-20k.Google Scholar

218 Gordon, Stacy L., A Better Tradition: Why Law Review Should Adopt a New Citation Format, 68 Mont. L. Rev. 175 (2007); Chin, supra note 207; Gallacher, supra note 69, at 14-18.Google Scholar

219 Dennis Fan, (June 20, 2014).Google Scholar

220 Weresh, supra note 79, at 776.Google Scholar

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222 Peter W. Martin, Introduction to Basic Legal Citation (LII 2012 ed.).Google Scholar

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226 The ALWD website shows its survey determined that 131 schools used the Bluebook exclusively, 19 schools used the ALWD exclusively, 10 both, 16 either and 8 others. ALWD Association of Legal Writing Directors website is available at (last visited Jan. 24, 2014); Gallacher, supra note 69, at 19 n.93 (in 2006, 91 schools were using the ALWD exclusively).Google Scholar

227 Lysaght & Tonner, supra note 225, at 1058. As of January 24, 2014, a total of 203 institutions are approved by the American Bar Association, ABA-Approved Law Schools, Available at http://www.americanbar.org/groups/legal_education/resources/abaapprovedlawschools (last viewed Jan. 21, 2014); Weresh, supra note 79, at 3.Google Scholar

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229 Bennett, Frank G., Citations Out of the Box, Creative Commons Attribution, 2013.Google Scholar

230 Linda J. Barris, Understanding and Mastering the Bluebook: A Guide for Students and Practitioners (Teachers manual) 1 (2011).Google Scholar

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234 Students complain that the first year of law school is a time of major information overload. While they are expected to absorb an enormous amount of new terminology and information on substantive law, they are equally expected to consume the very new and complex nature of legal citation, a foreign language all its own. Lysaght & Tonner, supra note 225. Legal citation can be a very frustrating process for the student and professor. Gerhardt, supra note 76. Another frustration for practicing lawyers is that the examples in the text use law-review typeface conventions rather than practitioner typeface conventions. Schiess, supra note 69, at 537. However, mastering the Bluebook is a manageable and attainable goal. And although mastering the Bluebook is confusing, having no “uniform system” of citation would indeed be worse. Barris, supra note 230, at 3. Robert Berring notes, “The Uniform System of Citation has inflicted more pain on more law students than any other publication in legal history.” Weresh, supra note 79 (quoting The Bluebook: a Sixty-Five Year Retrospective Vol. 2, app. A, 6 (1998)). Ultimately, you will be able to write most but not all citations without use of this manual. Some sources will drive even the most experienced legal writer back to the pages of the Bluebook or local citation guides. Martin, supra note 222. That is why the Bluebook is ultimately so useful because it provides a system so that everyone's citations are similar. Barris, supra note 230, at 3.Google Scholar

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244 Dickerson, Reducing, supra note 231, at 9. The main purpose of any legal citation is “to allow the reader to efficiently locate the cited source.” The Bluebook: General Principles of Citation, http://www.legalbluebook.com/Public/lntroduction.aspx. The Bluebook citation forms are designed to provide the information necessary to lead the reader directly to the specific items cited. Id. The editors of the Bluebook understand and acknowledge that, “no system of citation can be complete” because of the constantly increasing range of authorities cited in legal writing. Id. Therefore, they suggest when citing material not explicitly discussed in the Bluebook, that the writer “try to locate an analogous type of authority that is discussed and use that citation form as a model.” Id. at 3. And regardless of the citation manual the writer has to use to cite a source not available in the Bluebook, the writer should make every effort to “provide sufficient information to allow the reader to find the cited material quickly and easily.” Gerhardt, supra note 76.Google Scholar

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250 Id.Google Scholar

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252 Harvard Law Review launches online version of The Bluebook, http://www.law.harvard.edu/news/2008/02/25_bluebook.html.Google Scholar

253 Id.Google Scholar

254 Id.Google Scholar

255 Id.Google Scholar

256 Id.Google Scholar

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258 See, e.g., Wharton, Cathleen, Floyd, Daisy Hurst, and Downs, Bertis E. IV, Citation Form for Briefs and Legal Memoranda, The Center for Computer-Assisted Legal Instruction (Jan. 30, 2015), http://www.cali.org/lesson/561. CALI, the center for Computer-Assisted Legal Instruction, provides more than 100 interactive lessons and tutorials to help law students learn the law.Google Scholar

259 Id.Google Scholar

260 LexisNexis Research Help, http://web.lexis.com/help/research/gh_brief-check.asp (last visited May 10, 2014).Google Scholar

261 WestCheck, http://west.thomson.com/products/services/westcheck/default.aspx (last visited May 10, 2014).Google Scholar

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266 Id.Google Scholar

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