Guide for Journal Cite Checkers  

Keep these things in mind as you work on your cite check:

• Authors tend to be more focused on writing their text than on getting the footnotes just right. This means you’re likely to encounter incomplete or mistyped citations. Never fear! Most citation mysteries can be solved with just a little bit of sleuthing on the Internet, in law review datases, and/or in your author's files.

• Many authors are researching the same way you are, on the Internet. But your journal likely requires you to get hard copies or PDF images of sources. Luckily, more and more hard copies are being scanned and made available online. Keep in mind, though, that a source may exist only online and not in hard copy.  

• Start your source-gathering in Virgo, U.Va.’s online card catalog. It will tell you what books, journals, newspapers, and government documents we have at U.Va. If U.Va. doesn't have a source you need, you can borrow it from another institution's library through interlibrary loan.

• Contacting your author may be the best way to get an obscure source. If you have trouble finding a cited source, though, your readers probably will too. Consider whether an obscure publication, vanished website, or second-hand news article is the best source to support a point (sometimes it is), or if there is a more accessible and/or authoritative source that can be cited instead.

• Flip to the Bluebook's index to locate rules on how to cite specific sources. If a Bluebook rule is vague or confusing, search law review articles to see how other authors formatted their citations to the source (in particular, the Yale Law Journal and Columbia, Harvard, and University of Pennsylvania Law Reviews since their editors compile the Bluebook).  See also, Cite-Checker: A Hands-On Guide to Learning Citation Form (in the first floor Reserve Room at KF245 .B68 2008)and the Guide to Foreign and International Legal Citations (Reserve Room at K89 .G85 2009).

• Look up unfamiliar footnote abbreviations in the tables in the back of the Bluebook (Bluebooks are in the Reserve Room), the online Cardiff Index to Legal Abbreviations, or Prince’s Bieber’s Dictionary of Legal Abbreviations (in the Reference stacks at KF246 .B45 2009). 

• Get help! Stop by the Reference Desk on the Library’s second floor, or email us at lawlibref@virginia.edu.

Listed below are databases with PDF images of the types of sources you’re likely to be gathering. For cite checking purposes, downloading a PDF image is as good as having photocopied from the hardbound material yourself (so long as you're getting the PDF from a trusted source). Links to these databases are in the righthand column of this guide, and on the Law Library's homepage. Access databases from the comfort of your own home by configuring your computer for off-grounds access:

Cases

• WestlawNext has PDFs of cases printed in West’s hard copy reporters (e.g., Federal 2d, Atlantic 2d, Southeastern 2d). Pull up your case in WestlawNext, and click on the “original image” PDF link next to the case name.

• HeinOnline has PDFs of Supreme Court decisions from the U.S. Reports.  It also has United Kingdom cases printed in the English Reports (Eng. Rep.) from 1220-1827.

Statutes and regulations

• HeinOnline has the U.S. Code (current 2006 ed. and earlier versions), U.S. Statutes at Large (1789-2009, 111th Cong. 1st Session), C.F.R. (1938-2011), and Federal Register (1936-to date).

• The Government Printing Office’s documents website FDsys has PDFs of the C.F.R. (1996-2012), and Federal Register (1994-to date).

Congressional documents

• ProQuest Congressional has a comprehensive collection of committee reports, the Congressional Record and its predecessors, and congressional hearings from 1824 to 2003.

• HeinOnline also has the Congressional Record and its predecessors starting in 1789.

• FDsys has committee reports (starting 104th Congress, 1995-96), some hearings (starting 105th Congress, 1997-98), Congressional Record, and bills (starting 103rd Congress, 1993-94).

• Congressional committee reports are supposed to be parallel cited to the U.S. Code Congressional and Administrative News (U.S.C.C.A.N.) (Bluebook Rule 13.4). Be aware that U.S.C.C.A.N. includes only selected reports.  For reports not found there, go to the Serial Set on ProQuest Congressional or in hard copy in the Library.  Look at the spine of each Serial Set volume for the number of Congress (e.g., 112th for 2011-2012), chamber (House or Senate), type of government document (e.g., report), and document number (e.g., report number) that match your source. 

Journal articles

• Link directly to PDFs of articles from Virgo's “advanced article search.” If you can’t find a law journal article electronically, check our first floor stacks of law journals. If you can't find an article in a non-law journal electronically, use our Journal Finder to see if it is available in hard copy at a Main Grounds library and then take a field trip (and a Cavalier Advantage card for the copy machines). If U.Va. doesn’t have a journal, use interlibrary loan.

• HeinOnline has more than a thousand law reviews, most all the way back to the journal’s first year of publication.

• JSTOR has social science journals in addition to law reviews.

• For PDFs of recent articles, check journals’ websites.

• You can also link from Google Scholar to articles in U.Va. databases: click “find this @ UVA libraries” next to the article:

Newspaper articles 

The Law School Library gets the New York Times, Washington Post, Financial Times, Wall Street Journal, Richmond Times-Dispatch and Daily Progress every day, and keeps them in the Klaus Reading Room for one or two months.  If you need earlier articles, Alderman has the New York Times and Washington Post on microform, and Darden has the Wall Street Journal. Use our Journal Finder to locate other newspapers at U.Va.  For older newspaper articles try:

• ProQuest Historical Newspapers has the Chicago Tribune (1849-1988),Los Angeles Times (1881-1988), New York Times (1851-2008), Wall Street Journal (1889-1994), and Washington Post (1877-1995) in searchable PDF.

• America’s Historical Newspapers has selected issues of newspapers from cities nationwide, 1690-1991. Go to the “Newspaper Titles” tab to search within a particular publication. 

• Nineteenth Century Newspapers has selected issues of 19th Century newspapers from across the country.

*A few notes about citing online news articles & wire services: Online versions of newspaper articles sometimes differ from print versions.  If the article appeared only online and not in print, or if your author is citing material only in the online version of the article, cite it according to Bluebook Rules 16.6(f) and 18.2.2.  Articles from wire services (e.g., Reuters, Associated Press) should be cited to a print newspaper if they appeared in one, or to a database (e.g., Westlaw, Factiva) or webpage (see Bluebook Rule 16.6.(d)).

Documents from Court Cases (petitions, briefs, indictments, etc.)

• In WestlawNext, check the “filings” tab for PDF images of parties’ briefs. 

• BloombergLaw’s dockets database pulls federal court case documents directly from PACER, and also has documents from some state courts.

• For Supreme Court cases, try SCOTUSblog’s “merits cases” section for PDFs of briefs back to the 2007 Term, the American Bar Association website’s links to merits briefs from terms back to 2003, and the Making of Modern Law subscription database for cases from 1832-1978.

• Parties, especially organizations filing amici curiae briefs in a case, sometimes post their briefs on their website - Google!

If a source exists in print, Bluebook prefers that you cite to that (or to PDF or authenticated versions you find online). See generally Bluebook Rule 18.2. Here are some tips for when an author’s draft footnote gives you nothing to go on other than a link to a webpage:

• Check Virgo and WorldCat to see if the document exists in print. If so, cite to the print. If the document is available both in hard copy and online, cite to the hard copy and add an “available at” cite to the online version if it is identical to the print and “it will substantially improve access to the source cited” (see rule 18.2.3).

• If your author’s link isn’t to a PDF or official version of the document, check to see if one is available.

• If your author's URL leads you to a dead link, try shortening the URL to get to the website's main page and dig or search from there, or plug the document title into a search engine. Be aware that sometimes documents are taken down and never seen again. You can try to retrieve a vanished online source with the Internet Archive’s Wayback Machine.

Here are some examples of footnotes with Internet citations:

• Government publication with PDF available online – Your author’s draft footnote looks like this: See Table 1, Health Insurance Coverage by Type of Insurance and Age, CRS 96-891 (2005), http://assets.opencrs.com/rpts/96-891_20060830.pdf.  

• What is it?! A report by Congress’ research service (the Congressional Research Service (CRS)). Cite it as a federal legislative agency report according to Rule 13.4(d); CRS reports exist in print but are officially distributed just to Congress, so also include a parallel cite to the Open CRS webpage:  Chris L. Peterson, Cong. Research Serv., 96-891, Health InsuranceCoverage: Characteristics of the Insured and Uninsured Populationsin 2005 2 tbl.1 (2006), available at http://assets.opencrs.com/rpts/96-891_20060830.pdf. 

• Court document available in online database – Your author’s draft footnote: Complaint, McKee Foods Kingman, Inc., No. 3936614 (Westlaw), at 2 (E.D. Tenn. 2005).

• What is it?! A document filed in a pending court case, and the document is available on Westlaw.  Include a parallel cite to Westlaw (see rule 10.8.3): Complaint at 2, McKee Foods Kingman, Inc. v. Kellogg Company, No. 05-cv-254 (E.D. Tenn. Sep. 16, 2005), 2005 WL 3936614.

• Article available online only – Your author’s draft footnote:  Yahoo and Facebook Said to Settle Patent Lawsuits, N.Y. Times, July 6, 2012, available at http://dealbook.nytimes.com/2012/07/06/yahoo-and-facebook-said-to-settle-patent-lawsuits/.

• What is it?! An article posted in the New York Times’ online financial reporting service, DealBook (back out of the article link to DealBook's main page for general info about the source). Since it is online only and not a printed article, cite it directly to the Internet source under Rule 18.2.2:  Michael J. de la Merced, Yahoo and Facebook Said to Settle Patent Lawsuits, N.Y. Times DealBook (July 6, 2012, 1:10 PM), http://dealbook.nytimes.com/2012/07/06/yahoo-and-facebook-said-to-settle-patent-lawsuits/.  

• Treatise available in commercial database – Your author’s draft footnote:  Bruce E. Yannett, Foreign Corrupt Practices Act: An Overview, 1814 PLI/Corp 721 (2010).

• What is it?! An article included in one of the Practising Law Institute’s handbooks. Search Virgo to learn that U.Va.’s libraries don’t have a hard copy, and also search WorldCat to learn that it exists in hard copy at several other libraries. The article is readily available in Westlaw, so include the Westlaw identifier in your citation:  Bruce E. Yannett, Foreign Corrupt Practices Act: An Overview, in The Foreign Corrupt Practices Act 2010, at 721, 724 (PLI Corp. Law & Practice, Course Handbook Series No. B-1814, 2010), WL 1814 PLI/Corp 721.

Go first to Virgo, the U.Va. libraries' online card catalog, to find hard copies of books, journals, newspapers, and congressional documents here at U.Va. A combination of title/author keywords in the basic search box usually works, but don’t give up if your first search doesn’t show the result you need. Try another search with simpler keywords; also try the advanced search screen. Virgo results are ordered by relevance. Click on the hyperlink for the item for its location, availability, and a map of where it is in the stacks. Here are some Virgo tips:

• If an item is “unavailable” (Virgo-speak for checked out), click the “request unavailable item” link to recall it.  The person who has it should return it within 10 days.

• If an item is in “Ivy” (the library storage facility), click the “request items from Ivy” link; delivery usually takes just a couple of days.

• If Virgo says a book is on the shelf, but it’s not, first check to see if another cite-checker has it or if it is stashed it in your journal’s carrel.  Then check around the photocopiers, the re-shelving truck near the Reference Desk, and the re-shelving trucks at the Circulation Desk.

• If a book, bound journal volume, or microform you need is in a Main Grounds libraries, the Law School Library’s Student Delivery Service can pick it up for you and deliver it to the Law Library circulation desk.  Request up to two items at a time, and allow 2-3 days.

Remember to check out your books to your journal’s carrel before putting them in there!  If a book, book chapter, or journal article you need isn’t at U.Va., you can request it through Interlibrary Loan (ILL). Here’s how:

• Double-check Virgo to make sure the item isn’t at U.Va.

• Submit an online ILL request form: (1) login to get to the ILL request forms (your first time, click on the “first time users” button to set up your interlibrary services account; be sure to select Law as your Pick Up Library/Home Library); (2) choose the request form that matches your source (“borrow an item” for books, bound journals; “scan” for a chapter, article); (3) fill in as much information as you can, including the OCLC number and ISSN/ISBN number (see below); and (4) if you’re requesting a scan, use the drop-down menu at the top of the form to specify that your request is for a “law cite check.”  You'll get an E-mail either notifying you that your item has been delivered to the circulation desk or with a link to a PDF of it. Interlibrary loan requests usually take a week or more (requests for scans usually take less time). 

• Look up OCLC, ISSN, and ISBN numbers in WorldCat, the online catalog for libraries worldwide (search for items as in Virgo, using keywords for title/author).  Once you’re in an item’s detailed record, scroll down to find the ISSN/ISBN and OCLC numbers and plug these into your ILL request form.

Do draft footnotes like these look frustratingly familiar?

¹Speeding Access to Affordable Drugs, at 16 (July 20, 2006)

² Thurgood Marshall and the Law Library, 46 Okla. Law Journal (1993)

³ B. Schwartz, Earl Warren, at 17

⁴Donoghue, 1932 A.C. 562 (United Kingdom)

Sometimes a footnote you’re cite checking doesn’t give you enough information to locate the source, or has a misleading typo. To avoid a wild goose chase for the source: 

• First check the related text in the article for additional information you can plug into a Google and/or Virgo search for the source.  For example, if the text related to footnote 1 above mentioned a Senate Special Committee on Aging hearing, Google “speeding access affordable drugs hearing senate committee aging” and get results including a PDF of the hearing from the Committee’s website; run the same search in Virgo to find a hard copy of the hearing testimony in the library. Googling exact quotes your author includes from the mystery source often can lead you straight to it!

• If your author is citing a source, other authors probably have cited the same source.  Run a search with the information you have about the source in Westlaw, Lexis, or Google Scholar’s databases of law review articles.  For example, you’ve looked in the Oklahoma Law Journal but can’t find the law review article in footnote 2 above anywhere (not surprising, since the Journal hasn’t been published since the early 1900s, when Thurgood Marshall was still a very young child). Typos happen!  Running a search in Google Scholar for “Thurgood Marshall and the Law Library” retrieves the correct citation information to the Oklahoma Law Review:  Maria E. Protti, Thurgood Marshall and the Law Library, 47 Okla. L. Rev. 75 (1994).  Running the same keyword search in Virgo’s “article advanced search” also gets you the source information and a direct link to a PDF of the article.

• If searching online and in law review articles' citations doesn’t lead you to a source, hit the books via online card catalogs and e-books. Search Virgo first. If U.Va. doesn’t have a hard copy, run a search in WorldCat to see if another institution’s library has it and then request an interlibrary loan (you can make interlibrary loan requests for PDF scans of individual book pages and chapters). If your first couple searches don’t work, try several broader ones. For example, footnote 3: search Virgo for "Schwartz Earl Warren" to learn that Bernard Schwartz has written at least three books about him. You can check page 17 in each to see which supports your author’s text and/or search Google Books for previews of the books and supporting text.  

• Footnote 4's "1932 A.C. 562 (United Kingdom)" gives you enough information to flip to the United Kingdom in the Bluebook's Table 2 and see that you need to go to the Appeal Cases reporter ("A.C."), which you can locate through Virgo.

• If you can’t find a source published as an article, book, or government document, maybe it wasn’t published at all but was just posted online. Try looking for the document title in a search engine or on an organization’s website. 

This guide has quick tips to help you locate sources for your cite check and deal with hard-to-find sources and tricky citations.  

WestlawNext | Westlaw Classic

Lexis / LexisAdvance

HeinOnline Law Journals

Index to Legal Periodicals

   pre-1981 

1981+