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Cite-Checking: A Thousand Points of Citator-Speak


I recently asked law librarians for alternate, non-proprietary, ways of saying “Shepard’s” or “KeyCite” (or Shepardizing or KeyCiting). Below you’ll find a short list and a long list of responses, and not a few “namemushs.”

We focused primarily on case citators, but keep in mind you can cite-check a lot of things, including law review articles, court rules, statutes, and regulations (to name only 4).

What’s a citator? We like this concise description of Online Citators, from the University of Washington Law School librarians.

Short list of cite-check(ing) verbs and nouns:

Analyze the case’s treatment
Check precedential value
Checking for gotchas
Checking for losers
Citation update
Citator service
Judicial consideration
Legal research
Note-up (noting up)
Poor man’s Shepard’s (aka meatball Shepard’s, and vegan versions)
Search for subsequent history or negative history
Treatment analysis
Using a citator
Validate holdings
Validate opinion

Full list of responses, including from Canada and Australia, where one librarian commented on the latest generation of lawyers using variations of “citators” instead of previous generations’ use of “note-up”:

  • Using a citator. Citating. Cite-checking.
  • I think “cite check” is the way most people term it. The others are trademarks and shouldn’t be used generically anyway.
  • Would “note up” work?
  • Notionally (and somewhat humorously), from a former practitioner’s perspective, you could say “checking for gotchas,” or “checking for losers”—not just cases that are losers, but cases that will make your case [a] lose[r]. I’ve heard more than one story where a motion-hearing was won or lost on whether the caselaw used in argument was still good.
  • I say: use a citator, because you can check for the current authority status of a case, but you can also use a citator to expand your research universe
  • My impression is that for anyone serious about the process, cite-checking is called “legal research” because it is such an integral part of the process. In the same way that suturing the incision is part of what is called surgery, making certain that the law you read is actually the law is legal research.
  • Cite check works.
  • As I remember it they were referred to generically as Citators back a few decades ago.
  • I once got grief from Lexis for saying “poor man’s Shepard’s.
  • I usually say “updating” as a generic label for Shepardizing.
  • When I’m speaking generically, I use “citator service.”
  • To take the “Xerox” out of photocopy, or the “Kleenex” out of tissue, I would just refer to it as a citation update.
  • Canadian terminology includes: “judicial consideration”, “note-up.”
  • I call it a citator, and then have to explain “Like Shepards, Keycite, etc.” I’ve also called it a citation index, but “index” seems to confuse people nowadays. You could also do a namesmush, like Brangelina. Shepcite? Keyshep? Beypards, if you want to get Bloomberg Law in there?
  • Searching for subsequent history to a case.
  • I refer to it as searching for subsequent history to a case.
  • I say “citator” as a noun, but there is no good verb form – checking cites, validating cases, updating. Besides S and K, all the other smaller services offer some kind of citation service. B Cite (Bloomberg Law) also provides colored signals and analysis. The others don’t provide analysis (e.g., GlobalCite in Loislaw).
  • We say “check the subsequent history” or “check the negative history” when the circumstances warrant such a phrase. We mostly use the expression “authority check” when speaking generally about Shepardizing/Keyciting. We call those services “citators” so we occasionally say “citator check.”
  • I have heard one judicial assistant say “key-perdize” but most staff members use the generic or say “Shepardize” no matter if they’re using Lexis or Westlaw.
  • I’ve seen ‘citator’ used. The problem is that students don’t know what any of them really mean anyway….
  • I use ‘citate’ when teaching.
  • I call them citators to be neutral on the vendor. I did a survey of practitioners and had more than one respond that they would put a definition of citator at the top of the survey because it took them awhile to figure out what I meant. That and the fact that MS Word tries to change “citator” to “citatory” make me want to just show my bias and call everything Shepard’s!
  • I use the term citator.
  • I use “citationize.”
  • I use Validate.
  • “See if it’s good law” is what I hear a lot of lawyers say.
  • I use “citate” as well. Of course, every time I do spellcheck goes wild.
  • How about a portmanteau, such as keypardize or shepcite? In my opinion, it always depends on what you’re asking someone to do, namely do you want them to simply verify the later appellate history of an order or opinion or do you need to know the larger historical treatment? I’ve heard some suggest “treatment analysis” or “analyze this case’s treatment” as an alternative to mean both. Either way specificity is better because time is money and the former takes much less time than the later. “Citate” or “Cite check” to me also include verifying a case’s legal proposition and particulars (style, court, year, volume, page, jump page, etc.), which may not be what you’re after.
  • Update, check precedential value, validate holdings, validate opinion.
  • You’ve probably heard this from a million other sources by now, but I believe that the generic term for Shepard’s or KeyCite or BCite would be a citator. Or a citation index, if you prefer using more words.
  • We use “citators.”
  • Online citator service. From
  • Similarly, the noun I use as a catch-all is “citator” and it’s been the same term used by colleagues at a number of institutions.
  • We use ”Citators” to “validate” here.
  • In Australia, we call them ‘citators’ / ‘case citators.’ So if I were running a training session, I would say something like: ‘you can use a citator to find out where a case is reported and to find subsequent consideration of a case, so that you can check if it is still good law.’
  • Use the word “scrutinize” and when a confused student asks if you mean “shepardize” then you say “Quiet! Man, do you want to be sued?” (Original credit to The Simpsons).
  • I was always taught the Shepard’s was a ‘citator’ service. I always taught ‘citator’ checking.
  • Cite-check might be confusing because it is a Lexis batch checking program.
  • In Canada we “note-up” to find considerations or “update” to find appeals.
  • I’ll cast another vote for “citator” as the noun. I don’t really have a verb, I just say “use a citator”. I also let my students know that many people use “Shepardize” to refer to citator use generally, not just to the use of Shepard’s.
  • In law firms, we generally call the process “updating your research” and tools like Shepard’s and Keycite “citator services.” (These are the terms the senior partners use when giving this type of assignment to young associates, so we try to stay consistent.)
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