[The American Bar Association Special Committee on Citation Issues released this report in 1996]
SPECIAL COMMITTEE ON CITATION ISSUES
REPORT AND RECOMMENDATIONS
BE IT RESOLVED, that the American Bar Association 1
recommends that: 2
1. All jurisdictions adopt a system for official 3
citation to case reports that is equally effective for 4
printed case reports and for case reports electronically 5
published on computer disks or network services, that 6
system consisting of the following key elements: 7
A. The court should include the distinctive sequential 8
decision number described in paragraph C below in each 9
decision at the time it is made available to the public. 10
B. The court should number the paragraphs in the 11
decision. 12
C. The court should require all case authorities to be 13
cited by stating the year, a designator of the court, the 14
sequential number of the decision, and where reference is to 15
specific material within the decision, the paragraph number 16
at which that material appears. 17
D. Until electronic publications of case reports become 18
generally available to and commonly relied upon by courts and 19
lawyers in the jurisdiction, the court should strongly 20
encourage parallel citations, in addition to the primary 21
citation described in paragraph C above, to commonly used 22
printed case reports. When a cited authority is not available 23
in those printed case reports, the court should require 24
counsel to provide printed copies to opposing counsel and to 25
the court. The parallel citation should only be to the first 26
page of the report and parallel pinpoint citations should not 27
be required. 28
E. The standard form of citation, shown for a decision 29
in a federal court of appeals, should be: 30
Smith v. Jones, 1996 5Cir 15, 18, 22 F.3d 955. 31
1996 is the year of the decision; 5Cir refers to the United 32
States Court of Appeals for the 5th Circuit; 15 indicates 33
that this citation is to the 15th decision released by the 34
court in the year; 18 is the paragraph number where the 35
material referred to is located, and the remainder is the 36
parallel citation to the volume and page in the printed case 37
report where the decision may also be found. 38
2
REPORT
1 The Special Committee on Citation Issues submits the
following report concerning its recommendation to the House of
Delegates:
I. Charge to the committee.
2 In recent years, growing numbers of court decisions
have become available soon after their release, through
electronic publication on computer bulletin boards, disks, and
the Internet. The traditional method of citing to volume and
page numbers in printed reports cannot be used effectively for
these decisions because the printed reports typically are not
published until considerably later. In an effort to develop
citation methods that work effectively both with books and
with computer databases, a number of jurisdictions are
considering or have recently adopted new citation systems.
While there are similarities, these new systems differ
significantly among themselves.
3 The Board of Governors recognized the importance of
avoiding a proliferation of varying citation systems and
created this committee at the ABA Annual Meeting in August,
1995. The charge to the committee was:
The Committee shall (a) evaluate citation
issues, inviting views from all ABA entities
and organizations active in fields related to
legal citation; (b) develop recommendations
concerning a citation system which will be
broadly acceptable to the bar and to the
courts; and, (c) recommend action for
consideration by the Board of Governors and the
House of Delegates at the 1996 Annual Meeting.
II. The committee's study of citation issues.
4 The committee posted notices of its work on the ABA
Network home page on the Internet and wrote to invite written
submissions by interested individuals, ABA sections and
divisions, state bar associations, state and federal
judiciaries, the editors of the two leading citation manuals,
publishers of legal decisions, law libraries, and other
entities who had previously worked with citation issues. The
first invitation was issued on October 17, 1995, and the
period for submissions extended until May 5, 1996.
5 Based on the written submissions received by November
20, 1995, the committee selected entities and individuals to
3
provide further information in oral presentations in Chicago
on December 8, 1995. Those invited to make presentations
represented the entire spectrum of views as to positions the
ABA should take concerning citation issues. The following
entities and individuals made presentations:
ABA Section of Intellectual Property Law
Sabina Assar
Gary D. Spivey
American Association of Legal Publishers
Eleanor J. Lewis
Alan D. Sugarman
Association of Reporters of Judicial Decisions
Frederick A. Muller
State Bar of South Dakota
Thomas C. Barnett, Jr.
Taxpayer Assets Project
James Love
West Publishing Company
Donna Bergsgard
Brady C. Williamson
Wisconsin State Bar
John H. Lederer
Christopher G. Wren
Jill Robinson Wren
(individual Wisconsin lawyers)
6 The committee drafted an initial outline of its
report based on the written submissions received and the oral
presentations at its meeting on December 8, 1995. After a
number of revisions, a draft report was distributed for public
comment on March 18, 1996. Copies were sent to all who had
submitted material to the committee and to all who requested a
copy, and the report was made generally available through the
ABA Network.
7 The committee took into consideration all of the
information and comments it received by May 9, 1996, and
prepared this final report with recommendations for
consideration by the Board of Governors and House of Delegates
at the 1996 ABA Annual meeting.
8 The committee was fortunate to have the benefit of
the advice of liaisons from other organizations with
particular expertise and interest in citation issues. These
4
liaisons were:
Noel J. Augustyn, Esq.
Administrative Office of the United States Courts
The Honorable Danny J. Boggs
Judicial Conference of the United States
Professor Rita T. Reusch
American Association of Law Libraries.
The liaison members participated fully in the
meetings and discussions of the committee, but did not take
any part in the decisions of the committee as to its report
and recommendations. The members of the committee, who were
solely responsible for these decisions, and the entities from
which they were drawn were:
Robert W. Barger, Immediate Past Chair, ABA
Section of Science and Technology (New Jersey).
James E. Carbine, Co-chair, Trial Practice
Committee, ABA Section of Litigation
(Maryland).
J. D. Fleming, Jr., Chair (Georgia).
Professor Patricia B. Fry, Council Member, ABA
Section of Business Law (North Dakota).
Robert E. Hirshon, Chair Elect, ABA Tort and
Insurance Practice Section (Maine).
The Honorable Thomas S. Williams, Vice Chair,
Court Management and Administration Committee,
ABA Judicial Administration Division (Wisconsin).
Carolyn B. Witherspoon, President, Arkansas
Bar Association (Arkansas).
III. Summary of the Committee's Conclusions.
9 As directed by the Board of Governors, the committee
evaluated the citation issues which were raised in the written
and oral submissions it received. The primary issue of
concern was whether or not the committee should recommend a
new citation system which is not limited to references to
volume and page numbers in printed case reports.
10 Comments submitted to the committee showed
substantial agreement on certain core points. While
5
preferences were expressed for one form of citation or
another, there is general recognition that courts should be
and are free to prescribe a preferred or mandatory citation
method, including new methods which do not rely on the
traditional system of citing to volume and page numbers in
printed reports. (E.g., West Publishing's Statement of
Position to the American Bar Association Citation Issues
Committee, p. 12 (Nov. 17, 1995.)) There also is general
agreement that substantial uniformity of citation systems
should be encouraged for all jurisdictions. The major point
of disagreement is whether or not parallel citations to a
specific source, such as Lexis, Westlaw, or the West National
Reporter System, should be required in addition to a "generic"
and medium neutral citation. (Id.)
11 Based upon the information it received, the committee
recommends that courts adopt a universal citation system using
sequential decision numbers for each year and internal
paragraph numbers within the decision, these numbers being
assigned by the issuing court and included in the decision at
the time it is made publicly available by the court. The
committee also recommends that parallel citations to commonly
used print sources be strongly encouraged. This citation
system is equally adaptable to printed and electronic case
reports and is thus medium neutral.
IV. The Committee's Analysis of the Issues.
Issue No. 1: Is there a reason to change the existing citation
system?
12 The existing citation system is based on a volume and
page citation to a printed report of decisions. Some
jurisdictions have official reports and a number of commercial
vendors offer printed reports. These printed reports have
earned universal acceptance by courts and lawyers, and a
change in this citation system cannot be suggested absent a
clear and convincing reason. The committee has no doubt that
such a reason exists.
13 In recent years, computer-based technology has added
capabilities which are now commonly recognized as offering
significant improvements in the way that legal authorities are
published and disseminated. Few courts still use typewriters.
Decisions are largely prepared on computer word processors.
As a result, decisions are generated as computer files that
can be made available on online computer databases in a few
hours instead of the several weeks that are often required to
produce printed reports.
6
14 In addition to substantial improvement in the speed
of publication, electronic publishing offers significant
reductions in the bulk of case reports. Reports that would
require hundreds of volumes to print can be stored on a CD ROM
disk far smaller than a paper back book, allowing a lawyer to
carry a library and a computer to read it in a briefcase.
15 Another important factor is cost. For sole
practitioners and small firms as well as for large firms, the
current economic pressures on law practice demand that
overhead costs be controlled. The cost of making legal
research material available is therefore a key issue for most
lawyers. The cost of a CD ROM library is often a small
fraction of the cost of a printed library and the space it
occupies. This makes extensive collections of case reports
widely available in smaller towns as well as in the cities,
and significantly decreases the cost of those reports.
16 The committee recognizes that many lawyers prefer to
use printed case reports for legal research, and that printed
reports likely may remain the preferred source for some time.
Just as clearly, a number of examples demonstrate that the
publication of case reports is beginning to respond at an
accelerating pace to the lower cost and more prompt
availability of material that electronic publication makes
possible. As of January 1, 1996, the federal judiciary was
"in its seventh year offering various electronic public access
services to federal court information. . . . The federal
courts expect to complete the installation of an electronic
public access service into every federal appellate, district,
and bankruptcy court within the next several months. . . .
All federal circuit courts now offer public users electronic
access to appellate court decisions (slip opinions) and other
court information . . . ." (Directory of Electronic Public
Access Services, U.S. Federal Courts Home Page, Internet,
http://www.uscourts.gov.) All new Supreme Court and United
States Courts of Appeals decisions are available on searchable
databases soon after they are released. Some law journals are
now published only on the Internet, and not in print. South
Dakota is an example in which electronic publication of case
reports by a state bar association has made inexpensive
libraries available to all lawyers in the state at a modest
cost. At least one publisher of CDROM case reports has said
"we are in the process of expanding our coverage to all 50
states and adding federal coverage as well." (Brochure, LOIS,
Inc., page 3, January 1996.)
17 Examples such as these have convinced the committee
that the continued growth of electronic publication of case
reports is certain. It is clear that citation methods which
are satisfactory for printed reporters are not well suited to
electronic databases and reporters. The volume and page
7
numbers which describe very naturally where material can be
located in printed reporters are not meaningful or convenient
to apply to computer files, which are far more easily indexed
sequentially as they are released. In addition, requiring
electronic reports to use the page numbers from printed
reports is impractical since those page numbers are not
available until quite some time after the electronic report is
published. The adoption of a new citation method is essential
to allow electronic publication of case reports to reach its
full potential.
18 The committee concludes that it will be necessary to
adopt a new citation system suited as well to print
publication as to electronic publication. This new system
should be medium neutral in that it should be as easily used
with printed reports as with electronic reports. The
principal objective is to enhance the use of all forms of case
reports, and not at all to impede the use of printed reports.
19 The committee recommends that the new citation system
be applied to all decisions released to the public after the
date of adoption of the system by the court.
Issue No. 2: What citation convention should be specified for
reports of decisions?
20 As outlined in the following paragraphs, the
committee recognizes that any citation system that will be
equally useful for printed and electronic case reports must
depend on the assignment of specific references by the courts
at the time their decisions are released. The courts are in
the best position to decide what those references should be,
weighing such factors as administrative burdens and costs,
convenience for the courts and practicing lawyers, and the
advantages of uniformity among the various jurisdictions. The
committee's recommendations in the following paragraphs are
intended to suggest a beginning point for these decisions.
21 There are clear advantages to using a consistent
locator system for printed reports and for electronic reports.
This will allow lawyers and others to use the types of reports
that best suit their needs and preferences, and to use the
same citations in the works of a variety of publishers of
printed and electronic reports.
22 The use of a universal citation system throughout all
jurisdictions also has clear advantages. The free flow of
commerce encourages interstate business operations and the
result is that lawyers often practice in many different
jurisdictions and courts increasingly take advantage of
reasoned decisions from other jurisdictions. A system of
8
universal, permanent, immediately available citations for
electronic media will greatly ease the burden of those users.
23 In the following paragraphs, the committee has
suggested a specific format for the universal citation system.
While it is clear that some courts may find it necessary to
implement the system with modifications in the recommended
format, as noted in 20, the benefits from uniformity across
the nation will be realized only if the courts adopt
consistent formats whenever reasonably possible. The
committee would, for example, urge all federal courts of
appeals to use consistent court designators.
24 Some have suggested that reports be cited by case
docket numbers since these numbers could be used for
electronic reports as well as for printed reports. This
choice would entail several disadvantages, the most
significant of which is that multiple decisions in a case
would produce multiple reports with the same citation.
25 We recommend that each court assign distinctive
sequential indexing numbers to decisions it decides should be
released for general distribution to the public. These
sequential numbers can be used easily both in electronic
reporters and in printed reporters.
26 The committee recommends a universal system of citing
to a decision by stating the year, a unique designator
selected by the court, and a sequential number assigned to the
decision.1 This combination of identifiers creates a unique
designation of that decision. The committee suggests that all
jurisdictions adopt the mandatory use of this universal
citation system.
Fn 1. Each jurisdiction will decide which of
its decisions will receive a sequential
number designation. See 31.
27 An example of the decision designator in the uniform
citation system for a federal district court is:
Smith v. Jones, 1996 SDNY 15
in which 1996 is the year of the decision, SDNY is the United
States District Court for the Southern District of New York,
and 15 represents the 15th decision of the court during the
year.
28 Standard forms of other decision designators in the
uniform citation system are given in Appendix A.
29 The committee recommends the use of this citation
9
form by all state and federal appellate courts and trial
courts for which case reports are customarily published.
Issue No. 3: How should sequential decision numbers be
assigned?
30 The committee concludes that the courts in which the
cases are decided should control the assignment of sequential
decision numbers.
31 The committee recommends that each court assign a
sequential number to each decision that the court decides
should be released for general distribution to the public.2
The court may also wish to add brief supplemental signals to
the universal citation to give additional information such as
non-precedential decisions, NP, or "uncitable" decisions, U.3
An example is:
Smith v. Jones, 1996 9Cir 33 U.
Fn 2. All decisions, whether or not assigned a
number by the court indicating release for
general public distribution, are of course
public records and may be obtained by
anyone for any purpose from the clerk.
Fn 3. A decision not to number the decision
will not prevent its being cited, to the
extent permitted by the forum court, in
the same manner as formerly, for example
by docket number.
Issue No. 4: What locator should be used for pinpoint
citations within case reports?
32 The committee concludes that a uniform system of
pinpoint citation is highly desirable, for the same reasons
that support a uniform system of identifying decisions. With
the proliferation of case reporters, it is entirely possible
that the lawyers and the court may, in a given case, use
different sources for their legal citations. A common
reference point through a uniform system of pinpoint citation
will be of significant help in avoiding the confusion that
will result if different systems are in use among different
publishers and different jurisdictions.
33 Location markers in printed case reports have been
dependent on the format of the printed text, such as page,
column, or line numbers. A selection of one or two columns
per page, different page sizes, or different type fonts would
10
change the location marker at which particular text appears
within the report in various editions or formats.
34 For electronic case reports, the location markers
used for printed reports are less meaningful. In a word
processing file, for example, the page, column, or line
location can be changed immediately by selecting different
fonts or margins in the software. Fixed locators independent
of formatting may be specified in many ways, such as by an
arbitrary sequential number inserted after each 100 words of
the report, but most readers feel that these arbitrary markers
detract from printed reports.
35 One locator as suitable for printed reports as for
electronic reports is the beginning of a paragraph. The
committee concludes that the use of sequential paragraph
numbers, such as those used in this report, within case
reports offers a universal locator for case reports
independent of the medium. Paragraph numbers can be applied
easily, whether manually or through the use of a macro in a
word processing program. If errors occur, the result would
merely be that the locator is not quite as precise as it might
be, so that multiple paragraphs fall within a single paragraph
number, or that a single paragraph may be assigned more than
one number. In either event the locator is still considerably
more precise than a page number in a printed report and
therefore is more usable.
36 The committee recommends that all jurisdictions adopt
the use of paragraph numbers assigned by the court as locator
markers within decisions. The paragraph numbers should become
part of the official text of the decision.4
Fn 4. The use of the paragraph numbers is
illustrated in 40 below.
Issue No. 5: Should parallel citations be employed in addition
to the recommended universal citation?
37 Any new citation system must be designed to ease, not
impede, the access of courts and lawyers to case reports. The
system therefore should maximize the utility and comfort of
the citation system for those who prefer printed case reports
and for those who prefer electronic case reports. The
committee's approach to its recommendation concerning parallel
citations reflects this commitment.
38 The committee is convinced that over time, primary
reliance on printed case reports will shift to primary
reliance on electronic case reports. The duration of this
transition period is likely to be determined by the reaction
11
of the legal market. During the transition period, the
committee recommends that in addition to the universal
citation, all jurisdictions strongly encourage parallel
citation to a print source, if there is one that is commonly
used in the jurisdiction. Examples are a parallel citation to
U.S.P.Q. (United States Patent Quarterly), the West National
Reporter System, an official court reporter, and the BNA Labor
Relations Reporter. If the report is not available in
commonly used printed reporters, the committee recommends that
the court require copies of the decision to be furnished to
the court and opposing counsel.
39 The parallel citation should be to the beginning of
the decision in the format employed by the print source. As
noted in 47 through 49, publishers of printed reports have
incorporated paragraph numbers assigned by the court into
their reporters. Repeating the pinpoint citation in the
parallel citation is thus unnecessary.
40 An example of the recommended parallel citation form
for a federal court of appeals is:
Smith v. Jones, 1996 5Cir 15, 18, 22 F.3d 955.
Other standard forms are set out in Appendix A.
41 The paragraph number format used in this report
assists in locating a paragraph quickly, but some courts and
publishers have expressed a preference for a different format.
The Supreme Court of Canada, for example, uses numbers in the
margin without the paragraph symbol. West Publishing Company
uses paragraph symbols and numbers aligned with the left text
margin in printing the South Dakota reports. As long as the
paragraph numbers are easily recognized in the report of a
decision, any format will suffice. While the paragraph symbol
is readily typed using most word processing software, the
committee recommends that the use of a recognized alternative,
such as par., be permitted in a citation just as sec. is
widely accepted as an alternative to the section symbol, .
Issue No. 6: Primary contentions of proponents of the present
citation system.
42 Early in the committee's study, those who favored
retaining the present citation system without change suggested
many reasons for doing so. The committee considered these
suggestions at length and took them into account in arriving
at the system tentatively recommended by the committee in its
preliminary report. Some responses to the preliminary report,
which was widely distributed for public comment, expressed
very strong preferences for one system or another without
12
explaining the grounds for those preferences. A number of
comments recommended additional features or refinements of the
new system, but did not contend that the new system would be
seriously flawed. Only three primary arguments remained in
any significant number of comments opposing the system
recommended in the preliminary report. The committee does not
question the sincerity of the exponents of these arguments but
concludes that the arguments are not well founded.
43 The first argument was stated with admirable
precision by a judge. With reference to the existing citation
system, the judge said "If it ain't broke, don't fix it -- it
ain't broke."
44 The present citation system does function well for
conventional printed reports, as the committee recognized in
12. It does not, however, afford a citation suited to the
electronic publication of a court decision when it is first
released to the public. Printed volume and page numbers are
not available until weeks or months later. Requiring
electronic case reports to use these printed citation
references deprives users of the speed of publication, lower
cost, and lower space requirements of electronic case reports,
as is explained at length in 13 through 18. The universal
citation system recommended by the committee is intended to
meet this problem.
45 The second argument is that the recommended citation
system is a "citation to nowhere" because it does not identify
the source of the citation. In fact, the recommended citation
system is the ultimate citation to somewhere, because it is a
citation directly to the court's decision in the form in which
it was released by the court. The court assigns the decision
number and places the paragraph numbers when it releases the
decision to the public and files it in the record of the case.
Every citation using those reference numbers is a citation to
that original decision.
46 The last remaining argument is that formidable
burdens will be imposed if courts are responsible for
assigning sequential numbers to their decisions and numbering
the paragraphs. While this argument has been advocated with
skill, no factual support for it was offered to the committee.
Since several courts have already implemented such systems,
and major print publishers, including West Publishing Co.,
have begun printing reports using those systems, the committee
concludes that no insurmountable burdens are involved.
47 Many Canadian courts have used paragraph numbering in
their decisions for a number of years, and the Supreme Court
of Canada has numbered the paragraphs in its reports since
January 1, 1995. The committee was advised that
13
implementation of this system required only a few hours for
the first secretary to be trained in using a word processing
macro to place the numbers, and less than an hour to train
each of the other secretaries. The court reports the cost of
implementing this system as being modest. The paragraph
numbered reports released by the Supreme Court are used by
online services and almost all Canadian publishers of printed
case reports. Copies of a few pages from a decision of the
Supreme Court of Canada are attached.
48 The new citation system adopted by Louisiana uses
slip opinion page numbers instead of paragraph numbers. These
slip opinion page numbers are printed in the West National
Reporter System, along with West's own page numbers. Copies
of a few pages from the West reporter are attached. Louisiana
is pleased with its system and no significant problems with
its use have been reported.
49 South Dakota has adopted a system very similar to
that recommended by the committee. Copies of pages from a
South Dakota Supreme Court decision, the report of the
decision in WestLaw, the report in the CD ROM produced by the
State Bar of South Dakota, and the report published by West in
N.W.2d are attached. The committee is informed that no
substantial burdens were encountered in implementing the
system.
50 The experience of courts that have already
implemented citation systems similar to that recommended in
this report has convinced the committee that no substantial
burdens will be imposed on the courts or publishers by the
recommended system.
Special Committee on Citation Issues
J. D. Fleming, Jr., Chair
August 1996
14
APPENDIX A
Standard citations for representative types of
decisions are set out in this appendix. They are intended
only to be illustrative, not exhaustive.
The committee recommends that at the time of release,
each judicial decision should include a distinctive sequential
designation unique to that decision by stating the year, the
court designator and the sequential number of that decision
within the calendar year cycle. For state courts, the
committee recommends the use of two-letter postal codes.
(Example: 1996 MD 15 or 1996 WI 15). The following is a
series of examples of how the new universal form of citation
would work in a state court jurisdiction, accompanied by a
parallel citation to a print source.
1. Smith v. Jones, 1996 MD 15, 696 A2d 321.
2. Smith v. Jones, 1996 MD App 16, 696 A2d 436.
3. With a pinpoint citation: Smith v. Jones, 1996 MD 15, 23,
696 A2d 321.
4. With a citation to material in a footnote: Smith v. Jones,
1996 MD 15, n.4, 696 A2d 321.
5. Under the new system, a decision is "published" when it is
first released to the public. If later revised, the modified
decision or errata should be assigned a new sequential number.
Smith v. Jones, 1996 MD 15, 696 A2d 321, modified, 1996 MD 47,
697 A2d 457; Smith v. Jones, 1996 MD 15, 696 A2d 321, errata
1996 MD 47.
The recommended citation system is especially suited
to single court jurisdictions and can be made equally suitable
for multiple court jurisdictions, such as the federal court
system, by breaking down each larger jurisdiction into its
natural subparts. How the recommended universal form of
citation would work for the various federal jurisdictions is
shown by the following examples.
6. Supreme Court: Smith v. Jones, 1996 US 15, 124 SCt 432.
7. United States Court of Appeals for the Fourth Circuit:
Smith v. Jones, 1996 4Cir 22, 85 F3d 567.
8. United States District Court for the District of Maryland:
Smith v. Jones, 1996 DMD 17, 923 F. Supp. 835.
9. United States District Court for the Southern District of
New York: Smith v. Jones, 1996 SDNY 15, 922 F. Supp. 214.
15
10. For a federal court patent case the citation might be:
Smith v. Jones, 1996 EDVA 34, 23 USPQ2d 456.
Where courts in different locations are part of a
single system, they may well wish to draw their sequential
numbers from a central source rather than creating a sequence
for each location. The committee understands that some court
executives have concluded that inexpensive technology is
already available to assign numbers from a central computer
instantaneously over a phone line. This technology is widely
used at present to record credit card purchases and issue
approval numbers.
Other federal tribunals could use analogous
conventions.
11. The Tax Court: Smith v. Commissioner, 1996 TC 3.
12. The Occupational Safety and Health Review Commission:
Secretary of Labor v. Smith, 1996 OSHRC 7.
=============================================================
NOTE: Excerpts from the following decisions, mentioned in
47-49, were attached to the report filed with the House of
Delegates. Online sources are given below.
1. R. v. Edwards, 1996 Canada 24297, 1-7. Available through
the Internet at http://champlain.ic.gc.ca/opengov/
supreme.court/sc.home.html
2. Clement v. Frey, 1996 LA 95-C-1119, p1-3, 666 So.2d 607.
(Louisiana uses slip opinion page numbers rather than
paragraph numbers.) Available through Westlaw by entering fi
95-1119 (La. 1/16/96) and Lexis by searching for 95-1119.
3. Schroeder v. Department of Social Services, 1996 SD 34,
1-3, 545 N.W.2d 223. Available through Westlaw by entering
fi 1996 SD 34 and Lexis by searching for 1996 SD 34.
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