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Use Online Citators to Both Expand and Update your Research - Klovning

By Mark Kloempken & Tove Klovning

When should you use a citator?

You use a citator at the beginning of your research to find other cases and secondary sources that cite to your case and at the end of your research to make sure your case is still good law.  To ascertain if your case is still good law, you are looking at the ‘Direct History’ of the case.  If you have a case on point, what would you like to know about it?  Whether that case was affirmed, reversed or modified on appeal.  When you are looking at the ‘Direct History,’ you can also find out the prior history of the case, what happened to the case in a lower court.
 
The ‘Indirect history’ of the case is how other courts have treated your case.  While the action of subsequent courts in distinguishing the holding of the original case will not affect the holding as it applies to the original parties, it can affect whether or not you can use the case to support your argument.  Indirect history is also a research tool, to find other material on your topic: law reviews, treatises, Attorney General Opinions and other secondary sources.  At the beginning of your research process use the citator to find other cases and secondary material that cite to your case.  
 
So, when should you use a citator?  You use a citator at the beginning of your research to find other resources discussing your case.  You use a citator at the end of your research to ensure that your case is still good law.