Today, the North Carolina Supreme Court issued an order rescinding its 2020 order implementing a “universal citation” system.

The change has to do with this question: How do you cite to a recently issued case? Sure, the Westlaw and Lexis citations come out fairly quickly. But it can take weeks (or longer) before the North Carolina Appellate Reporter or the South Eastern Reporter Second citations are finalized.

The North Carolina Supreme Court came up with a solution a couple of years back: “Universal Citation.” The idea was for opinions to “have an immediate, permanent, and medium-neutral (‘universal’) citation the moment they are issued.”

But what about pinpoint citations? Don’t you have to wait for the text to be formatted for some reporter before you can identify the page number where that great quote appears? The Universal Citation system had a solution for that as well: numbered paragraphs appearing in the opinion itself from the start.

As the Supreme Court explained in a press release issued today, it turns out that it was more difficult than expected to insert those paragraph numbers in the opinions. Happily, though, the North Carolina Appellate Reporter has “made improvements to the speed at which official reporter citations are available electronically to lawyers and the public.”

Against that backdrop, the Supreme Court decided to step back from universal citation, for now. “The Court will continue to evaluate the universal citation concept with the expectation that the system could be relaunched in the future.”

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