Back in June, the Supreme Court of North Carolina sought feedback on a potential change to the citation format for North Carolina appellate court opinions. This week, the Court has officially made plans for the universal citation format to go into effect. The purpose of the change is to present “an immediate, permanent, and medium-neutral” citation the moment an opinion is issued.
Under the new format, each opinion will contain a unique opinion number and paragraph numbers that will be native to the text. The official opinions will still be in the North Carolina reporters. Proper case citations will therefore include the following: the case name, a citation to the North Carolina reporter, the new universal citation, and (as appropriate) a pinpoint citation to a particular paragraph. For example:
State v. Smith, 257 N.C. App. 43, 2021-NCCOA-23, ¶ 8
The change is effective at the beginning of 2021, which will give the courts, the clerks, and practitioners time to work out the details–and come to grips with the change.
The Supreme Court’s administrative order announcing the change can be found here. Let us know your thoughts, and what questions you have, in the comments below.
–Kip Nelson