¹ Notre Dame Law School Honor Code See § 2.3.2 in Appendix A.Google Scholar

² Black's Law Dictionary 1335 (10th ed. 2014).Google Scholar

³ Black's Law Dictionary 1187 (8th ed. 2004) (quoting Paul Goldstein, Copyright's Highway: From Gutenberg to the Celestial Jukebox 12 (1994)).Google Scholar

⁴ Under the “fair use” copyright provisions, copyrighted materials may be reproduced for news reporting and educational use. 17 U.S.C. § 107 (2000). In particular, the fair use statute allows “the fair use of a copyrighted work, including such use by reproduction in copies or phonorecords or by any other means specified by that section, for purposes such as criticism, comment, news reporting, teaching (including multiple copies for classroom use), scholarship, or research, is not an infringement of copyright.” Id.; Kindergartners Count, Inc v. DeMoulin, 249 F. Supp. 2d 1233, 1251-52 (D. Kan. 2003) (quoting Black's Law Dictionary 1170 (7th ed. 1999) (quoting Paul Goldstein, Copyright's Highway 12 (1994))); Robert D. Bills, Plagiarism in Law School: Close Resemblance of the Worst Kind?, 31 Santa Clara L. Rev. 103, 108-09(1990).Google Scholar

⁵ 17 U.S.C. § 102(a), (b).Google Scholar

⁶ Id. §§ 107-109; Bills, supra note 4.Google Scholar

⁷ See Stephen Weidenborner & Domenick Caruso, Writing Research Papers: A Guide to the Process 91 (1982) (defining plagiarism as “[a] kind of theft whereby one writer steals the ideas or exact words of another writer without giving credit where it is due”).Google Scholar

⁸ Charles Cronin, Columbia Law Sch., Presentation at Colby College Conference on Information Ethics and Academic Honesty, Plagiarism, Copyright, Academia and Commerce 4 (Oct. 15, 2003), available at http://abacus.bates.edu/cbb/docs/Cronin.pdf.Google Scholar

⁹ For example, see Western State University, University of Hawaii, and Boston University School of Law. See W. State Univ. Honor Code § 201(b)(9). Western State University's Honor Code defines plagiarism as the “incorporation of written work, either word for word or in substance from any work of another, unless the student writer credits the original author and identifies the original author's work with quotation marks, notes, or other appropriate written designation.” University of Hawaii at Mānoa William S. Richardson School of Law, Policy on Plagiarism (2006) 2. The submission or presentation of any work, in any form, that is not a student's own, without acknowledgment of the source. A student must not appropriate ideas, facts, or language from the work of another without proper use of quotation marks, citation or other explanatory insert. Regardless of intent, the failure to properly acknowledge the use of another's work constitutes plagiarism.” Boston University School of Law Disciplinary Regulations Regarding Plagiarism. All written work, whether in preliminary or final form, submitted by a student in the course of law study, in the course of employment, or in the course of other activities, whether or not related to the study or profession of law, is assumed to be the student's own work. Anything copied or paraphrased from another author or sources must be appropriately identified, acknowledged, and attributed. The use of exact language of another without identification as a direct quotation by quotation marks or otherwise is plagiarism even though the source is cited in the student's work. Similarly, the University of Virginia has a 150-year-old honor code, which is absolute. The Honor Committee University of Virginia recently passed guidelines regarding paraphrasing and plagiarism. Mark Gruntz and another college student, Allison Routman, were expelled from the Semester at Sea program for violating the university's honor code. See Susan Kinzie, An Education in the Dangers of Online Research, Wash. Post, Aug. 10, 2008, at C5, available at http://www.washingtonpost.com/wpdyn/content/article/2008/08/09/AR2008080901453_pf.html. Gruntz had failed to sufficiently cite Wikipedia in a paper about a movie. Id. Some of the students at the university were outraged and formed a petition protesting the verdict, while others felt that it was justified. Id. The debate was partly generational between those who grew up with the Internet versus those who did not. Id. Many “baby” Internet users thought the punishment was too harsh. Regardless of the spectators’ opinions, the verdict stood. Id.Google Scholar

¹⁰ See analysis from Texas directors & AALL list serve; Terri LeClercq, Failure to Teach: Due Process and Law School Plagiarism, 49 J. LEGAL EDUC. 236, 236 (1999); see Plagiarism Resources, Legal Writing Inst., http://wiki.lwionline.org/index.php/ Plagiarism (last visited Jan. 1, 2014).Google Scholar

¹¹ I have had discussions with several other law librarians and law professors over the years. The comments provided are from Elizabeth M. (Betsy) McKenzie, Professor of Law, Suffolk University Law School, BA, Transylvania University; JD, MSLS; email on file with author.Google Scholar

¹² Id.Google Scholar

¹³ Law Library Directors Listserve Julie Clement, Charles Calleros, Ralph Brill, Mary Barnard, and Jane Scott.Google Scholar

¹⁴ Survey question posted by Irene Crisci on the AALL Academic Law Libraries SIS Digest on April 9, 2013;Google Scholar

¹⁵ Spencer Simon, Director of the Law Library and Associate Professor of Law O'Quinn Law Library University of Houston Law Center.Google Scholar

¹⁶ David Cowan, Professor of Law and Director of the Library Services and Vice President, South Texas Law School, retired.Google Scholar

¹⁷ Gail Daly, Associate Dean for Library and Technology and Associate Professor of Law Underwood Administrative Offices.Google Scholar

¹⁸ Barbara A. Bintliff, Director of the Tarlton Law Library/Jamail Center for Legal Research and the Joseph C. Hutcheson Professor in Law; Wayne Schiess, Director of the David J. Beck Center for Legal Research, Writing, and Appellate Advocacy, http://www.lwionline.org/publications/plagiarism/policy.pdf.Google Scholar

¹⁹ Id.; see also Legal Writing Inst., Law School Plagiarism v. Proper Attribution, available at http://www.tsulaw.edu/student_affairs/docs/plagiarism.pdf 2003.Google Scholar

²⁰ Ronald B. Standler, Plagiarism in Colleges in USA: Legal Aspects of Plagiarism, Academic Policy (2012), available at http://www.rbs2.com/plag.pdf (accessed Jan. 17, 2013).Google Scholar

²¹ Miguel Roig, Avoiding Plagiarism, Self-plagiarism, and Other Questionable Writing Practices: A Guide to Ethical Writing 3, available at http://ori.hhs.gov/images/ddblock/plagiarism.pdf (last visited Feb. 17, 2014).Google Scholar

²² Plagiarism is not the only form of academic misconduct committed by students. Anytime a student's work impedes the professor's ability to correctly assess the student's academic performance, it warrants some measure of punishment. If a student submits a paper, copying or paraphrasing all the material and correctly attributing the sources, then it would not be plagiarism. However, the paper would lack “original thought” and warrant a failing grade because it would impair a professor's ability to assess the student's academic performance. Mary M. McCormick, Plagiarism, Lack of Original Thought, Double-Dipping, and Student Drafts 6 (2007), available at http://www.law.fsu.edu/library/databases/pdf/plagiarism.pdf. Further, when a student submits the same or slightly-reworked paper in two different courses this also prevents the faculty member from assessing the student's academic performance in the current class. Id. Such double-dipping is not allowed in course work; however, law schools, most publishers, law reviews and journals allow a paper to be recycled, if it is “of sufficiently greater scope or depth.” Id. at 7.Google Scholar

²³ Legal Writing Inst., Law Student Plagiarism: You Can't Afford It!, available at http://www.law.umaryland.edu/dept/academics/writing/documents/plagarism.pdf.Google Scholar

²⁴ Worthen, Kevin J., Discipline: An Academic Dean's Perspective on Dealing with Plagiarism, 2004 BYU Educ. & L.J. 441, 442 (2004) (quoting K.R. St. Onge, The Melancholy Anatomy of Plagiarism 39 (Rowman & Littlefield 1988)).Google Scholar

²⁵ See Yarbrough, Marilyn V., Do As I Say, Not As I Do: Mixed Messages for Law Students, 100 Dick. L. Rev. 677, 678 (1996).Google Scholar

²⁶ See Doe v. Conn. Bar Examining Comm., 818 A.2d 14 (Conn. 2003).Google Scholar

²⁷ Beauchene v. Miss. Coll., 986 F. Supp. 2d 755 (S.D. Miss. 2013).Google Scholar

²⁸ Id. at 759.Google Scholar

²⁹ Id. at 760.Google Scholar

³⁰ Id. at 762.Google Scholar

³¹ Id.Google Scholar

³² Id. at 763.Google Scholar

³³ Valente v. Univ. of Dayton, 438 F. App'x 381, 383 (6th Cir. 2011).Google Scholar

³⁴ Id. at 386.Google Scholar

³⁵ Id. at 385-88.Google Scholar

³⁶ Id. at 388.Google Scholar

³⁷ Yu v. Univ. of La Verne, 126 Cal. Rptr. 3d 763, 766-68 (Cal. Ct. App. 2011).Google Scholar

³⁸ Id. at 768.Google Scholar

³⁹ Id. at 773.Google Scholar

⁴⁰ Id. at 773-74.Google Scholar

⁴¹ Id. at 774.Google Scholar

⁴² In Di Lella v. Univ. of D.C. David A. Clarke Sch. of Law, 570 F. Supp. 2d 1 (D.D.C. 2008).Google Scholar

⁴³ Id. at 4.Google Scholar

⁴⁴ Id. at 5.Google Scholar

⁴⁵ Id. at 5, 11–12.Google Scholar

⁴⁶ Seitz-Partridge v. Loyola Univ. of Chi., 987 N.E.2d 34 (Ill. App. Ct. 2013).Google Scholar

⁴⁷ Id. at 36.Google Scholar

⁴⁸ Id. at 37.Google Scholar

⁴⁹ Id. at 46.Google Scholar

⁵⁰ Marten v. Godwin, 445 F. App'x. 65, 66 (10th Cir. 2011).Google Scholar

⁵¹ Id. at 67.Google Scholar

⁵² Id. at 68.Google Scholar

⁵³ Id. at 69.Google Scholar

⁵⁴ Hart v. Univ. of Scranton, 838 F. Supp. 2d 324, 325 (M.D. Penn. 2011).Google Scholar

⁵⁵ Id.Google Scholar

⁵⁶ Id. at 326.Google Scholar

⁵⁷ Id. at 327-29.Google Scholar

⁵⁸ Wayne, Jaber v., State Univ. Bd. of Governors, 788 F. Supp. 2d 572, 573 (E.D. Mich. 2011).Google Scholar

⁵⁹ Id. at 573.Google Scholar

⁶⁰ Id. at 573-74.Google Scholar

⁶¹ Id. at 574.Google Scholar

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⁶³ Id.Google Scholar

⁶⁴ Gilbert v. Des Moines Area Cmty. Coll., 495 F.3d 906, 912 (8th Cir. 2007).Google Scholar

⁶⁵ Id.Google Scholar

⁶⁶ Id. at 913.Google Scholar

⁶⁷ Id. at 915.Google Scholar

⁶⁸ Id. at 919.Google Scholar

⁶⁹ Chicago survey of law firm issues with new student's arguments judges often stops presentations and request the authority. First year students participating in the law review write-on process are eager to learn citing in law review articles, footnotes, or endnotes. Also, a 1994 survey of Texas appellate judges and clerks concluded that “'citation form [was] so wrong as to be distracting'” and in a 2003 survey the judges polled found citation mistakes to be common problems in legal writing. Wayne Schiess, Ethical Legal Writing, 21 Rev. Litig. 527, 536 (2002) (quoting Pamela Stanton Baron & Douglas W. Alexander, Briefing to the Texas Courts of Appeals and the Texas Supreme Court—Avoiding Common Mistakes, Fourth Annual Conference on Techniques for Handling Civil Appeals in State and Federal Court 15 (Univ. Tex. Sch. Law 1994)); Ian Gallacher, Cite Unseen: How Neutral Citation and America's Law Schools Can Cure Our Strange Devotion to Bibliographical Orthodoxy and the Constriction of Open and Equal Access to the Law, College of Law Faculty Scholarship (2007), available at http://surface.syr.edu/cgi/viewcontent.cgi?article=1001&context=lawpub. In particular, they determined the absence of citation error more important than the absence of punctuation or spelling errors. Gallacher, 2 n.9 (quoting Susan H. Kosse & David ButleRitchie, How Judges, Practitioners, and Legal Writers Teachers Assess the Writing Skills of New Law Graduates: A Comparative Study, 53 J. Legal Educ. 80, 90 (2003)).Google Scholar

⁷⁰ E.g, Kapco Mfg. Co. v. C & O Enters., Inc., 886 F.2d 1485, 1496 (7th Cir. 1989) (sanctioning an attorney whose “briefs misrepresented propositions of law in legal treatises and misrepresented facts”); Wallace Computers Servs., Inc. v. David Noyes & Co., No. 93 C 6005, 1994 WL 75201, at *1 (N.D. Ill. Mar. 9, 1994) (trial court chastised defense counsel for repeatedly citing authority “in an inappropriate, out of context manner”); Federated Mut. Ins. Co. v. Anderson, 991 P.2d 915, 922 (Mont. 1999) (dismissing appeal for, among other reasons, inaccurate citations to authority); Carrier v. Salt Lake Cnty., 104 P.3d 1208, 1213-14 (Utah 2004) (discussing whether to strike pleadings as a result of inaccurate record citations and inadequate citation of legal authority).Google Scholar

⁷¹ See Judith D Fischer, The Role of Ethics in Legal Writing: The Forensic Embroiderer, the Minimalist Wizard, and Other Stories, 9 Scribes J. Legal Writing 77, 77 (2003) (citing Tyler v. State, 47 P.3d 1095, 1108 (Alaska Ct. App. 2001)).Google Scholar

⁷² See In re Lamberis, 443 N.E.2d 549, 553 (Ill. 1982). This Illinois Supreme Court censured an attorney for incorporating nearly verbatim two published works into his L.L.M. thesis without attribution. Id. The court found that the plagiarism could not go undisciplined because honesty is a fundamental function of the legal profession. Id. In Iowa, an attorney was suspended for six months and ordered to pay the costs of the disciplinary action. Iowa Sup. Ct. Bd. of Prof l Ethics & Conduct, 642 N.W.2d 296, 302 (Iowa 2002). The attorney copied 18 published pages from a treatise into his brief and then sought $16,000 in attorney's fees for 80 hours of work preparing the brief. Id. at 298. When the judge questioned the brief's content, Lane attempted to conceal his actions. He was found guilty of plagiarism, for attempting to deceive the court, and, thereby, “jeopard[izing] the integrity of the Bar and the public's trust of the legal profession.” Id. at 302. Also, in USA Clio Biz, Inc. N.Y. State Dep't of Labor, an attorney was ordered to show cause why he should not be sanctioned for his brief that repeated large sections almost verbatim from another brief. No. 97 CV 250, 1998 WL 57176 (E.D.N.Y. Jan. 3, 1998). In Dewilde v. Guy Gannett Publ'g Co., the attorney copied large portions of his opposing counsel's memorandum into his brief. 797 F. Supp. 55 (D. Me. 1992). In Federated Mutual Insurance Co. v. Anderson, 920 P.2d 97 (Mont. 1996), a law firm was sanctioned for providing misleading and selective quotations that were often taken out of context or omitted a critical phrase, and for citing cases that supported the opposite proposition for which they were cited. Id. at 102. In Columbus Bar Ass ‘n v. Farmer, 855 N.E.2d 462 (Ohio 2006), Respondent Farmer filed a brief, which was a nearly verbatim recasting of the brief prepared by the previous attorney on the case. Id. at 465. The panel suspended the attorney for two years, required him to refund his client all but $1,000 of the $8,915 fee collected and ordered him to pay the cost of the proceeding. Id. In In re Hinden, 654 A.2d 864 (D.C. 1995), an attorney was reprimanded for pasting ten pages from an A.L.R. annotation into his brief without citation. The court was particularly annoyed by the attorney's thrown-together brief that aided neither the lawyer's client nor the court. In Alamo v. Puerto Rico, No. 05-1955, 2006 WL 1716422 (D.P.R. June 19, 2006), Mr. Nolla-Acosta, counsel for plaintiff, submitted a brief that contained more than seven pages of text copied nearly word-for-word from another supreme court's opinion, without any citation to that case. Id. The court found the plagiarism, “for which we can only guess Mr. Nolla-Acosta actually billed his client, is unacceptable.” In this case, the attorney violated two major rules, because he plagiarized and then provided an unearned fee for the disservice.Google Scholar

⁷³ In re Brennan, 447 N.W.2d 712, 714 (Mich. 1989).Google Scholar

⁷⁴ Id. at 713-14.Google Scholar

⁷⁵ Vice President Joe Biden presents the best example of how plagiarism can haunt one for a lifetime. In 1965, Biden committed his first act of plagiarism as a first year law student at Syracuse University College of Law. E. J. Dionne Jr., Biden Admits Plagiarism in School But Says It Was Not ‘Malevolent,' N.Y. TIMES, Sept. 18, 1987, available at http://www.nytimes.com/1987/09/18/us/biden-admits-plagiarism-in-school-but-says-it-was-not-malevolent.html.Biden plagiarized part of a paper he wrote in his legal methods course from a law review article entitled “Tortious Acts as a Basis for Jurisdiction in Products Liability Cases” that was published in the Fordham Law Review. Id. His law school record indicated that “five pages of Biden's 15-page paper were copied without quotation or attribution.” Jack Shafer, What Kind of Plagiarist Is Joe Biden? The Unusually Creepy Kind, Slate (Aug. 26, 2008), http://www.slate.com/articles/news_and_politics/press_box/2008/08/what_kind_of_plagiarist_isjoe_biden.html. Although Biden's first plagiarism charge eventually appeared to be just a bad memory, it returned to haunt him in his 1987 and 2008 presidential campaigns when a second charge of plagiarism surfaced. This time Biden was accused of taking major parts of a speech by British politician Neil Kinnock and incorporating it into his campaign speech. Id. Upon disclosure, this action became the downfall of his campaign. Although many may not have been aware of either incident, the information resurfaced during his 2008 presidential campaign and continued to haunt him.Google Scholar

⁷⁶ Gerhardt, Deborah R., Plagiarism in Cyberspace: Learning the Rules of Recycling Content with a View Towards Nurturing Academic Trust in an Electronic World, 12 Rich. J.L. & Tech. 1, 10 (2006).Google Scholar

⁷⁷ McKiggan, John, Supreme Court of Canada Upholds Judge's “Copycat” Decision (in Part): Cojocaru v. British Columbia Women's Hospital and Health Centre, Med. Malpractice Law. Blog (May 29, 2013), http://www.halifaxmedicalmalpractice-lawyerblog.com/2013/05/supreme_court_of_canada_uphold.html.Google Scholar

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⁷⁹ Austin, Arthur D., Footnotes as Product Differentiation, 40 Vand. L. Rev. 1131, 1135 (1987) (quoting Axel-Lute, Legal Citation Form: Theory and Practice, 75 Law Lib. J. 148 (1982)); cf._ Melissa H. Weresh, The ALWD Citation Manual: A Coup de Grace, 23 U. Ark. Little Rock L. Rev. 775, 805 (2001) (quoting Miles O. Price, A Practical Manual of Standard Legal Citations (1958)).Google Scholar

⁸⁰ Weresh, supra note 79.Google Scholar

⁸¹ Bills, supra note 4, at 130.Google Scholar

⁸² Fischer, supra note 71, at 88; The Bluebook: A Uniform System of Citation, Bl, at 3 (19th ed. 2010) [hereinafter Bluebook].Google Scholar

⁸³ Alan L. Dworsky, User's Guide to the Bluebook: Revised for the 19th Edition 1 (2010). “The writing of history is a rich process of building on the work of the past with the hope that others will build on what you have done. Through footnotes you point the way to future historians.” Doris Kearns Goodwin, How I Caused That Story, Time, Jan. 27, 2002. A successful legal argument convinces the listener that a sound legal and factual basis for the position advocated actually exists. However, if the argument lacks citation, or if the citations are inaccurate, the reader will dismiss the argument because it is not properly supported by authority. Bills, supra note 4, at 130.Google Scholar

⁸⁴ Schiess, supra note 69.Google Scholar

⁸⁵ They explain how primary authority is the law; while secondary authority explains, interprets and provides citations to the law. Christina Kunz et al., The Process of Legal Research : Authorities and Options (8th ed. 2012). In most legal writing and research classes, this knowledge is used to conduct legal research needed to draft memoranda and briefs. Thurgood Marshall School of Law for example first year legal writing and research students are required to write a closed memoranda then an open memorandum then a brief and attribute all authority. When the first memo is returned, the flow of red ink quickly reminds them that they must provide authority to support their arguments.Google Scholar

⁸⁶ Fischer, supra note 71, at 88.Google Scholar

⁸⁷ Bluebook B4.1.Google Scholar

⁸⁸ Contento, Lurene, Freeing Students to Write More Effectively: Taking the Fear Out of Plagiarism, The Second Draft, Fall 2011, at 26.Google Scholar

⁸⁹ Bauerlein, Mark, The Dumbest Generation: How the Digital Age Stupefies Young Americans and Jeopardizes Our Future (2008); Thomas H. Benton, On Stupidity: A cartload of recent books suggests that it's time to reverse the customer-service mentality plaguing academe, Chron. Higher Educ., Aug. 1, 2008, available at http://chronicle.com/article/On-Stupidity/4 5764.Google Scholar

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⁹¹ Nicholas Carr, The Big Switch: Rewiring the World, From Edison to Google (2013).Google Scholar

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⁹⁵ Id.; Berrett, Dan, Students Come to College Thinking They've Mastered Writing, Chron. Higher Educ, Mar. 21, 2014, available at http://chronicle.com/article/Students-Come-toCollege/145473/. This writing instructors’ survey revealed key differences between what students assume about writing and what faculty members expect; Council of Writing Program Administrators, Framework for Success in Postsecondary Writing (2011), available at http://wpacouncil.org/files/framework-for-success-postsecondary-writing.pdf; Robin Wilson, Lowered Cites, Chron. Higher Educ., Mar. 21, 2014, at A26 (see statistics on “Not Afraid to Give Themselves Credit”); Grammarly: Best Plagiarism Checker & Proofreader. Grammarly is an automated proofreader and plagiarism checker that corrects up to 10 times as many mistakes as other word processors. http://www.grammarly.com/?q=lagiarism-&utm_source=google&utm_medium=cpc&utm_campaign=SimilarUsers&utm_content=28330765206&utm=&matchtype=&placement=www.thenational.ae&network=d&gclid=CKTvjZmPor8CFa9r7AodPSo A-Q.Google Scholar

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⁹⁸ Jones, Steve, The Internet Goes to College: How Students Are Living in the Future with Today's Technology 8 (2002), available at http://www.pewinternet.org/files/oldmedia/Files/Reports/2002/PIP_College_Report.pdf.Google Scholar

⁹⁹ Steven A. Lastres, Rebooting Legal Research in a Digital Age 2 (2013), available at http://www.llrx.com/files/rebootinglegalresearch.pdf Google Scholar

¹⁰⁰ Id.Google Scholar

¹⁰¹ The most commonly used index for periodicals is the Reader's Guide to Periodical Literature, sometimes called the Reader's Guide to Periodicals, or Reader's Guide.Google Scholar

¹⁰² CLI & ILP are legal periodical indexes.Google Scholar

¹⁰³ Electronic indexes Infotrac or Academic Search Premier and LegalTrac. (The Gale Group, a Thomson Company, provides Infotrac College Edition; Gale LegalTrac provides indexing for approximately 875 titles including major law reviews, legal newspapers, bar association journals and international legal journals: contains indexing for over 8,000 publications, with full text for more than 4,450 of those titles.)Google Scholar

¹⁰⁴ Survey Results on file with DeCarlous Spearman TMSL First year Legal Bibliography class Fall 2008.Google Scholar

¹⁰⁵ Jones, supra note 98.Google Scholar

¹⁰⁶ Pearson, Gretchen, “Part title.” Electronic Plagiarism Seminar, Syracuse, Mar. 23, 2005, http://www.lemoyne.edu/library/plagiarism.Google Scholar

¹⁰⁷ Gerhardt, supra note 76.Google Scholar

¹⁰⁸ The Center for Academic Integrity, CAI Research, (Apr. 4, 2006)). Mark Ellis, Copycat: Don't Click That Mouse!; Stealing Someone's Writing Is Plagiarism, Columbus Dispatch, Mar. 30, 2005, at 1G; see also Sara Rimer, A Campus Fad That's Being Copied: Internet Plagiarism Seems on the Rise, N.Y. Times, Sept. 3, 2003, at B7.Google Scholar

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¹¹⁰ Id. (citing Jones, supra note 98, at 12).Google Scholar

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¹¹² Boston University School of Law Regulations.Google Scholar

¹¹³ Id.Google Scholar

¹¹⁴ Student, Serendip, Procrastination: Habit or Disorder?, http://serendip.brynmawr.edu/bb/neuro/neuro02/web1/jmaryasis.html (modified Apr. 29, 2013).Google Scholar

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¹¹⁸ Head, Allison J., Op-Ed, Old-schoolJob Skills You Won't Find on Google, The Seattle Times, Dec. 8, 2012, available at http://seattletimes.com/html/opinion/2019857185_allisonheadopedxml.html.Google Scholar

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¹²³ Garner, Bryan A., Why Lawyers Can't Write Science Has Something to Do with It, and Law Schools Are Partly to Blame, A.B.A. J., Mar. 2013, at 24. Garner asserts that “lawyers on the whole don't write well and have no clue that they don't write well”; Joan Catherine Bohl, Generation X and Y in Law School: Practical Strategies for Teaching the “MTV/Google” Generation, 54 Loy. L. Rev. 775, 776 (2008). Bohl describes her versus her research assistant's relationship with technology: “Her relationships with technology is clearly different from mine. She is a digital native; I'm a digital immigrant.” Professor Barbara Iverson, a professor of new media at Columbia College, coined the phrase in an article by Natalie Y. Moore, Rule of Thumbs: Love in the Time of Texting, Wash. Post, Sept. 16, 2007, at B1. Bohl commented, “I struggle to master my computer's quirks and to translate its obscure message into something I can understand. She … learned its language as she learned English. She approaches technology armed with intuition…. This is the other half of the equation facing law school professors today…. The language of the digital universe is a second language to the boomer generation, and to the earliest members of generation X. Our students are native speakers.” Bohl, supra at 776-77.Google Scholar

¹²⁴ Gerhardt, supra note 76.Google Scholar

¹²⁵ “Mosaic or ‘patchwork’ plagiarism is when a writer does not directly copy another's work, but instead changes a few words or slightly reorganizes some sentences. Though mosaic plagiarism is not a word-for-word account of someone else's work, it uses many of the ideas and concepts in an obvious way.” Leslie Nierste, Three Kinds of Plagiarism, eHow, http://www.ehow.com/info_7986111_three-kinds-plagiarism.html#channel=f20428e4bc76414&origin=http%3A%2F%2Fwww.ehow.com (last visited Oct. 15, 2013); see also Definitions/Plagiarism, Academic Integrity, http://webs.purduecal.edu/integrity/dishonesty/definitions-plagiarism/; What Constitutes Plagiarism? Harvard Guide to Using Sources. http://isites.harvard.edu/icb/icb.do?keyword=k70847&pageid=icb.page342054; Bowdoin Office of the Dean of Student Affairs, Common Types of Plagiarism, http://www.bowdoin.edu/studentaffairs/ academichonesty/common-types.shtml.Google Scholar

¹²⁶ Harris, supra note 90.Google Scholar

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¹²⁹ “Digital Natives” are those that were “born after 1980, when social digital technologies, such as Usenet and bulletin board systems, came online.” John Palfrey & Urs Gasser, Born Digital: Understanding the First Generation of Digital Natives 1 (2008).Google Scholar

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¹⁴⁰ Id. at 40.Google Scholar

¹⁴¹ This is something that I noticed in class, but also see David Glenn, Divided Attention: In an Age of Classroom Multitasking, Scholars Probe the Nature of Learning and Memory, Chron. Higher Educ, Feb. 28, 2010, at 2; John Palfrey, Digital Natives go to Law School, Harv. L. Sch. Faculty Workshop 2010 (Mar. 1, 2010), available at http/www.law.harvard.edu/faculty/faculty-workshops/john.palfrey.spring.2010.faculty.workshp.pdf.Google Scholar

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¹⁴³ Bast, Carol M. & Samuels, Linda, Plagiarism and Legal Scholarship in the Age of Information Sharing: The Need for Intellectual Honesty, 57 CATH. U. L. Rev. 777, 784 (2008); Jonathan Bailey, Self-Plagiarism: Ethical Shortcut or Moral Scourge? Plagiarism Today (Sept. 7, 2011), http://www.plagiarismtoday.com/2011/09/07/self-plagiarism-ethical-shortcut-or-moral-scourge/.Google Scholar

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¹⁴⁹ Jaschik, Scott, Vigilante Justice on Plagiarism, Inside Higher Educ. (Nov. 13, 2008), http://www.insidehighered.com/news/2008/11/13/tamiu.Google Scholar

¹⁵⁰ Id.Google Scholar

¹⁵¹ SafeAssign™ Plagiarism-Checking Service, www.lexisnexis.com/lawschool (last visited June 28, 2014).Google Scholar

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¹⁵⁶ LeClercq, supra note 146, at 239, 250.Google Scholar

¹⁵⁷ Young attorneys entering law firms are expected to draft legal documents and are often directed to formbooks to retrieve sample documents they can edit to fit the facts of their client's case. Practicing attorneys often incorporate the use of formbooks in their legal drafting. In the practice of law, this text is freely borrowed and recycled without attribution. Gerhardt, supra note 76.Google Scholar

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¹⁵⁹ 37 C.F.R. § 202.1(c).Google Scholar

¹⁶⁰ See Bibbero, 893 F.2d at 1106.Google Scholar

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¹⁶² Id.Google Scholar

¹⁶³ Tracy L. McGaugh & Christine Hurt, Interactive Citation Workbook for The Bluebook: A Uniform System of Citation (Lexis 2009).Google Scholar

¹⁶⁴ Id.Google Scholar

¹⁶⁵ Id.Google Scholar

¹⁶⁶ Gerhardt, supra note 76.Google Scholar

¹⁶⁷ University of Hawaii at Mānoa William S. Richardson School of Law, Policy on Plagiarism, at 10.Google Scholar

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¹⁶⁹ Bluebook R.1.1(b)(ii), at 53.Google Scholar

¹⁷⁰ Martin, Brian, Plagiarism: A Misplaced Emphasis, 3 J. Info. Ethics 36-47 (1994), available at http://www.uow.edu.au/~bmartin/pubs/94jie.html. When a citation is used after paraphrased work, it alerts the reader that the original author's information has been restated and gives credit to the original author. This removes any potential charge of plagiarism.Google Scholar

¹⁷¹ University of Hawaii at Mānoa William S. Richardson School of Law, Policy on Plagiarism, at 10. Under an exception to this rule, some legal scholars omit a citation when the idea can be found in five or more independent sources.Google Scholar

¹⁷² Bluebook R. 10, at 87-109.Google Scholar

¹⁷³ Id. R. 1.2, at 54-56. When a signal is incorporated, it should be accompanied by a parenthetical describing the relevance of the source. The citation and signal combination give credence to the purpose for citing the authority.Google Scholar

¹⁷⁴ Johnson, Tom, How to Write an Essay: 10 Easy Steps 59, Aug. 2004, available at http://www1.aucegypt.edu/academic/writers/.Google Scholar

¹⁷⁵ Bluebook R. 10.6.2, at 100.Google Scholar

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¹⁷⁷ Dickerson, Darby, Footnoting Law Review Competition Papers, 30 Stetson L. rev. 477, 478 (2000).Google Scholar

¹⁷⁸ Bales, Richard A., Footnotes, 68 Bench & Bar Kentucky 41 (2004). Citations should not be the transition for a sentence. Test the substance of the citation.Google Scholar

¹⁷⁹ Id.Google Scholar

¹⁸⁰ Seligmann, Terry Jean & Seymour, Thomas H., Choosing and Using Legal Authority: The Top Ten Tips, 6 Persp. 1 (1997), reprinted in The Best of Perspectives 73 (2001).Google Scholar

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¹⁸³ Id.Google Scholar

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¹⁸⁵ Id.Google Scholar

¹⁸⁶ Rodell, Fred, Goodbye to Law Reviews, 23 Va. L. Rev. 38 (1937); Fred Rodell, Comment, Goodbye to Law Reviews—Revisited, 48 Va. L. Rev. 279 (1962); see also Jack M. Balkin, The Footnote, 1989, Faculty Scholarship Series, Paper 287 (some law students, lawyers, and legal academics believe, “footnotes are the real measure of worth in legal writing”), available at http://digitalcoomons.law.yale.edu/fss_papers/287. However, students should be aware that overusing footnotes or using textual footnotes can be distracting. Bales, supra note 178. Cramming six footnotes into one sentence may increase an academic author's footnote and tenure chances, but it is unlikely to enhance a reader's understanding of the material. Bales, supra note 178. Noel Coward, once said: “Having to read a footnote resembles having to go downstairs to answer the door while in the midst of making love.” G.W. Bowersock, The Art of the Footnote, 53 American Scholar 54, 54 (1984).Google Scholar

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¹⁹⁰ Id.Google Scholar

¹⁹¹ Gerhardt, supra note 76.Google Scholar

¹⁹² Schiess, supra note 69, at 541; Westinghouse Elec. Corp. v. NLRB, 809 F.2d 419, 425 (7th Cir. 1987).Google Scholar

¹⁹³ Westinghouse, 809 F.2d at 425.Google Scholar

¹⁹⁴ Id.; Gerhardt, supra note 76.Google Scholar

¹⁹⁵ Van Winkle v. Owens-Corning Fiberglas Corp., 683 N.E.2d 985, 989-90 (Ill. App. Ct. 1997).Google Scholar

¹⁹⁶ Id.Google Scholar

¹⁹⁷ Schiess, supra note 69, at 536. Pinpoint citation is also called a jump citation, dictum page, or pincite. Black's Law Dictionary 278 (9th ed. 2009).Google Scholar

¹⁹⁸ Dickerson, Darby, Citation Frustrations—And Solutions, 30 Stetson L. Rev. 477, 507 (2000).Google Scholar

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²⁰¹ Gerhardt, supra note 76, at 16. When you fail to refer readers to specific pages where the referenced material appears, readers become frustrated. Scheiss, supra note 69, at 537. Pinpoints are valuable to anyone who reads and checks legal authority because without pinpoints, the checker's job is much more complicated. Id.Google Scholar

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²⁰⁵ Bryan A. Garner, The Elements of Legal Style 85 (2d ed. 2002).Google Scholar

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²¹¹ Id. at 19.Google Scholar

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²²⁶ The ALWD website shows its survey determined that 131 schools used the Bluebook exclusively, 19 schools used the ALWD exclusively, 10 both, 16 either and 8 others. ALWD Association of Legal Writing Directors website is available at (last visited Jan. 24, 2014); Gallacher, supra note 69, at 19 n.93 (in 2006, 91 schools were using the ALWD exclusively).Google Scholar

²²⁷ Lysaght & Tonner, supra note 225, at 1058. As of January 24, 2014, a total of 203 institutions are approved by the American Bar Association, ABA-Approved Law Schools, Available at http://www.americanbar.org/groups/legal_education/resources/abaapprovedlawschools (last viewed Jan. 21, 2014); Weresh, supra note 79, at 3.Google Scholar

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²³⁴ Students complain that the first year of law school is a time of major information overload. While they are expected to absorb an enormous amount of new terminology and information on substantive law, they are equally expected to consume the very new and complex nature of legal citation, a foreign language all its own. Lysaght & Tonner, supra note 225. Legal citation can be a very frustrating process for the student and professor. Gerhardt, supra note 76. Another frustration for practicing lawyers is that the examples in the text use law-review typeface conventions rather than practitioner typeface conventions. Schiess, supra note 69, at 537. However, mastering the Bluebook is a manageable and attainable goal. And although mastering the Bluebook is confusing, having no “uniform system” of citation would indeed be worse. Barris, supra note 230, at 3. Robert Berring notes, “The Uniform System of Citation has inflicted more pain on more law students than any other publication in legal history.” Weresh, supra note 79 (quoting The Bluebook: a Sixty-Five Year Retrospective Vol. 2, app. A, 6 (1998)). Ultimately, you will be able to write most but not all citations without use of this manual. Some sources will drive even the most experienced legal writer back to the pages of the Bluebook or local citation guides. Martin, supra note 222. That is why the Bluebook is ultimately so useful because it provides a system so that everyone's citations are similar. Barris, supra note 230, at 3.Google Scholar

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²⁵⁹ Id.Google Scholar

²⁶⁰ LexisNexis Research Help, http://web.lexis.com/help/research/gh_brief-check.asp (last visited May 10, 2014).Google Scholar

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²⁶⁹ Topol, Eric, The Coming Revolution How Technological Advances Will Radically Transform Health Care, U.S. News & World Report, Best Hospitals 14 (2014). Joseph Schumpeter was an Austrian economist in the mid-20th century. His efforts were taken very seriously and therefore Schumpetered meant the level of completeness and thoroughness one pursued.Google Scholar

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