Legal Definitions - parallel citation

A parallel citation refers to providing multiple references to the exact same legal document, most commonly a court case, as it appears in different published collections of legal decisions. This practice is common because a single court decision might be published in an official government-issued reporter and also in one or more unofficial, commercially published reporters. Each part of a parallel citation directs a reader to the identical text of the court's decision, but in a different set of books or a different legal database.

Here are some examples to illustrate this concept:

• Example 1: U.S. Supreme Court Case

  Imagine a lawyer citing the landmark U.S. Supreme Court case Gideon v. Wainwright, which established the right to counsel for indigent defendants in felony cases. A full parallel citation for this case might appear as: 372 U.S. 335, 83 S. Ct. 792, 9 L. Ed. 2d 799 (1963).

  This illustrates a parallel citation because:

  • "372 U.S. 335" refers to Volume 372 of the United States Reports (the official reporter for Supreme Court decisions), starting on page 335.
  • "83 S. Ct. 792" refers to Volume 83 of West's Supreme Court Reporter (an unofficial commercial reporter), starting on page 792.
  • "9 L. Ed. 2d 799" refers to Volume 9 of the United States Supreme Court Reports, Lawyers' Edition, Second Series (another unofficial commercial reporter), starting on page 799.

  All three citations point to the identical text of the Supreme Court's decision in Gideon v. Wainwright, but in different published sources.

• Example 2: State Appellate Court Case

  Consider a hypothetical decision from a state's court of appeals, for instance, the case of Patel v. City of Springfield, decided by the California Court of Appeal. A parallel citation for this case might be: 25 Cal. App. 5th 123, 234 Cal. Rptr. 3d 456 (2018).

  This demonstrates a parallel citation because:

  • "25 Cal. App. 5th 123" refers to Volume 25 of the California Appellate Reports, Fifth Series (the official reporter for California appellate court decisions), starting on page 123.
  • "234 Cal. Rptr. 3d 456" refers to Volume 234 of West's California Reporter, Third Series (an unofficial commercial reporter that includes California appellate decisions), starting on page 456.

  Both citations lead to the same judicial opinion, allowing legal professionals to find the case in whichever reporter they have access to.