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CSL, Metadata, and Legal Information that Just Works
Legal citation, Legal citations, Legal descriptive metadata, Legal metadata 5 Responses »
In the wake of a decisive victory at the Battle of Sekigahara in 1600, Tokugawa Ieyasu treated rival Japanese warlords to a simple but effective instrument of control, pioneered in the preceding Era of the Warring States. The Daimyo, as the defeated clan heads were known, retained control of their respective domains, but were required to reside in the newly established seat of government at Edo (now Tokyo) in alternate years. They were free to return home in the off-years, but only by leaving their princesses and heirs behind in the walled gardens of the capitol, as a token of the enduring bond of friendship and mutual admiration that united the Shogun and his sometimes grudging subordinates.
The processions of competing Daimyo moving to and from the seat of real power soon became a measure of status, and the cost of these semi-annual journeys would eventually consume fully half of each Daimyo's disposable income. This contributed greatly to the prosperity of communities stationed along the wayside, where tradesmen, innkeepers, chefs, entertainers, and the occasional thief shared in revenue extracted from the peasants in the Daimyo's fiefdom back home. A cynic might say that the practice of san-kin-kōtai (参勤交代) was little more than an elaborate system of hostage-taking, but in its way it was very good for business — at least if you did not have the misfortune to be a peasant.
Japan later shed the hobbles of feudal regulation, of course, and the population are now free to move about as they please; but for Daimyo read content, and for the Daimyo's princesses and progeny read metadata, and you have a description of a familiar Internet business model. Too familiar, perhaps, as most of us now rely on content supplied through walled gardens for much of our research work.
Just as the freedom of individuals is improved by lifting restraints on travel, so the flow of content is more meaningful when accompanied by the descriptive metadata that is its natural companion. As observed by others in this space (most recently here and here), there are barriers today to the free flow of legal information. As will be outlined below, hamstrung metadata is, unfortunately, one of them. This information — mundane details like the date, court, and party names of a legal decision, and the volume, journal, page or identifier used to locate it — are curiously hard for machines to find in the pages issued by any of the leading commercial services in the 40-year-old online legal information industry.
More than any fundamental difference in the materials themselves, captive metadata accounts for the striking gap that has emerged between the research tools available in law and in other disciplines. Driven by the needs of researchers in the sciences and the humanities, personal research platforms that thrive on metadata are now widely available: to make them servants of the law, they want only to be fed.
One element of this alternative infrastructure that depends on rich metadata provision is the Citation Style Language (CSL), which is the proper subject of this essay. The next three sections provide a short introduction to CSL, followed by a few observations on the state of legal metadata provision on today's legal Internet. The essay concludes with a comment on some of the lights that seem to be flickering into view at the end of this particular tunnel, and on the prospective benefits of at last bringing the law within reach of a modern research support ecosystem.
The Citation Style Language is an XML vocabulary for accurately describing citation and bibliography formats. Given the breath of life by the original Zotero citation formatter, CSL is now entering its eighth year of development, can boast two full production implementations, and drives citation formatting in at least six major bibliographic or text processing projects, with total user numbers in the millions.
The illustration to the right provides a simplified view of CSL processing flow. In greater detail it works like this:
A running copy of the processor is cast ("instantiated") using the rules specified in a particular CSL style file.
The calling application sends fine-grained item metadata to the processor.
The processor registers data it receives, for the purpose of tracking the document context of each item.
The calling application sends a request for a citation or a bibliography listing. In the former case, the call will supply information about document state (note numbers and the like), and additional details specific to the request (such as a pinpoint page number).
The processor analyses the request, calculates any auto-generated item variables, and applies any disambiguation rules defined in the style to assure that item references are unique.
The processor returns the citation or bibliography listing as a serialized string in the language (such as English or French) and the markup format (such as XHTML or RTF) that it has been configured to deliver.
The upshot of all this swirling machinery is that generic metadata can be used to generate citations in arbitrary formats. In operation, this means that an article originally written according to, say, the Oxford Standard for Citation of Legal Authorities (OSCOLA) can be reformatted on the fly to conform to the requirements of, say, the McGill Guide, or perhaps the Australian Guide to Legal Citation (PDF) or the ALWD Manual. This functionality is used daily by researchers in most fields worldwide, and there is no reason the law should be an exception.
The automated generation of citations is just one benefit of this processing flow; it also enables the embedding of cited metadata directly in the source document (for sharing between collaborators), and it allows links to referenced resources to be attached at the point of production (for ease of referencing after publication). Hints of resistance from some quarters notwithstanding, such tools clearly promise to save law professors, law students, lawyers, court clerks, judges, and others who must do legal drafting a tremendous amount of time.
Formatting citations
There are a few commonly-encountered wrinkles in legal data and citation styles that CSL and the citeproc-js formatter have been carefully designed to address. To give readers a glimpse of this work, a few basic elements of the language are laid out below. We'll begin with the following sample citation in the OSCOLA style: Jones & others v Wright [1991] 3 All ER 88.
The bare case name can be produced with the following construct:
<text variable="title" font-style="italic" strip-periods="true"/>
(Note the use of font-style="italic" to render the variable content in italic type, and of the strip-periods="true" attribute, which will be discussed below.)
The year element can be produced with the following code:
<date variable="issued" form="text" date-parts="year" prefix="[" suffix="]"/>
(Note the use of prefix and suffix.)
To build the full cite, we join these and other elements together by wrapping them in a group element and setting a single space as the delimiter. In the example below, we also define this construct as a macro, so that it can easily be reused in multiple contexts in the style:
<macro name="oscola-case">
<group delimiter=" ">
<date variable="issued"  form="text" date-parts="year"
prefix="[" suffix="]"/>
<number variable="issue"/>
<text variable="container-title"/>
<text variable="page-first"/>
</macro>
If we want to use this cite form for English legal cases only, we can wrap it in a condition:
<choose>
<if type="legal_case" jurisdiction="gb" match="all">
<text macro="oscola-case"/>
</choose>
(Note the type, jurisdiction and match attributes, and the use of a text node with a macro attribute to call our macro.)
With the code above, we will obtain something close to our target cite format if we arrange for the calling application to feed the processor JSON input like the following:
"container-title": "All England Law Reports",
"date": {
"date-parts": [["1991"]]
"issue": "3",
"page": "88",
"title": "Jones & others v. Wright"
Looking carefully at this input, we can see that there are some small discrepancies in the metadata:
the period after the v; and
the full name of the reporter.
These details can be handled automatically in the processor. The first issue is trivial: quashing periods is a general requirement of OSCOLA, and this one will be removed by the strip-periods="true" attribute that we set on the title element. The second issue requires a bit of further explanation.
Applying abbreviations
In our sample input, the journal name has been spelled out in full to avoid ambiguity. This is an example of best practice, although the field content does differ from our desired output of "All ER". The current version of Zotero provides a journalAbbreviation field for each item, but this has known limitations, and is not suitable for legal writing.
Many styles require that commonly cited journal names, at least, be abbreviated. Some styles have mandatory and idiosyncratic abbreviation requirements. As Judge Posner commented recently (PDF) concerning the requirements of Bluebook: A Uniform System of Citation: It's as if there were a heavy tax on letters, making it costly to write out Coast Guard Court of Criminal Appeals instead of abbreviating it … There is no tax on letters, of course, but the lack of a truly uniform system of abbreviation means that such elaborate schemes impose a significant cost in their own right. In Zotero, if journal abbreviations are registered directly on individual items in the user's personal library, they must be entered manually for each item, both when the original item is created, and each time the user wants to generate citations in a different style. This is not acceptable: metadata should be generic.
With a view to squaring the needs of users with those of the more demanding styles, the citeproc-js processor allows arbitrary abbreviation lists to be registered and managed on a per-style basis.
Here's how it works. When the processor encounters a field that requests form="short", it looks for the field content in an externally-supplied abbreviation list derived from a small (persistent) database. If there is no match, the processor opens an empty entry for the field in its (ephemeral) run-time registry. In an application that draws on this functionality, the user can visit the run-time listing at any time, and enter suitable abbreviations. These are then registered in the persistent external database, where they are remembered for future use with the current style.
In our case, the user would enter "All ER" as the journal abbreviation, and the application would store and deliver auxiliary input like the following:
"container-title": {
"All England Law Reports": "All ER"
Abbreviations list support has not yet been implemented in mainstream projects, but I have built a small Firefox add-on for use with Zotero that draws upon it, and I am happy to report that it does work, as advertised, both for journal abbreviations, and for other similar purposes (such as "hereinafter" support).
In our CSL code, invoking the abbreviation list machinery requires only a small change to the citation macro:
<text variable="container-title" form="short"/>
A full style will be more elaborate, but the basic logical structures are the same, with conditional statements used to select simple nested groups of nodes that describe the output to be produced.
I'll draw a line under the technical discussion at this point, but you get the idea.
CSL is an elegant and expressive language that has grown under the tutelage of strict demands from academics and graduate students in many fields. The language is fully documented in the CSL Specification. The proposed extensions for full legal support, documented in the citeproc-js CSL Specification Supplement, have been carefully formulated, and I am open to feedback. Style development is proceeding apace, and increments and milestones are being reported through the CitationStylist.org website, which serves as a clearinghouse for legal and multilingual style development. From experience with the first target style for full implementation (the Creative Commons licensed OSCOLA), the prospects for CSL style support for legal resources that "disappears", as such tools ought to do, are very bright.
Input from the Web
In addition to bringing us open-source community-driven citation formatting technology, Zotero offers one-click acquisition of content, to a full-featured personal electronic library on the user's desktop. This is handy, even essential, in today's world of overabundant information sources. It is facilitated by the fact that in most fields of study, aggregator sites have a long history of providing access to structured metadata from their pages.
The server-side technology that enables one-click content acquisition well predates the Internet. Libraries that run their catalogs on the 1980's MARC standard or one of its variants can and often do expose these records to the Internet. Aggregators in the sciences typically provide BibTeX records, which researchers have relied upon since the original format was frozen in 1988. Booksellers and publishing consortia offer metadata keyed to ISBN numbers, and the publishers of academic and other journals participate in the DOI system for assigning unique IDs keyed to canonical metadata for individual articles. The world of academic discourse is swimming in rich, life-giving metadata. Until, that is, one arrives on the salted shores of the law, where there is no water, and precious little sand.
The metadata story on the paywalled sites is very straightforward: exposing it would not be in the vendor's commercial interest, so there isn't any. It's hard to fault the logic. Even if we insist on the unflattering feudal analogy with which this essay opened, it's worth remembering that Japan's Shogunate endured for 250 years before finally giving way to change. Business opportunities don't come much better than that, and one can hardly expect the leading providers to react any differently.
There is variety in the ecosystem, however, and not all suppliers of legal source are driven by the same pattern of economic incentives. Providers that expose their content with metadata stand to benefit from CSL and other infrastructure-in-waiting, which can significantly raise the real value of their service. To state the point more precisely: supplying fine-grained metadata is essential for a publisher's content to be attractive to third-party reference management tools like Zotero — it's important enough to be in the project's guidance notes.
This is a separate point from the movement for universal or format-neutral citation formats. Promotion of these is also important, but from the perspective of data acquisition, they are not sufficiently uniform across jurisdictions to serve, by themselves, as primary metadata for a general research platform. As a well-intended example, consider this tag embedded in a case from CanLII:
<meta name="DC.Title"
content="Smith v. Jones, 2003 CanLII 19166 (NWT RO)"/>
In order to register this item in a reference manager database, we need to know what each of the elements means. This will be obvious to a local practitioner, but a Zotero page translator would need to include hand-crafted pattern-matching functions to parse out the elements and assign them to field variables. If I were doing the coding (ignorant as I am of Canadian law), I would be stumped by several of these elements:
From the size of the number, I guess that it is a document identification number, but if it were smaller, I might mistake it for a page number. That could result in my misclassifying the cite as one to a printed reporter, and that in turn could affect the formatting of pinpoint identifiers in styled output generated from the harvested data.
This appears to be a geographic identifier (Northwest Territories?), but I am not sure. I am also unsure whether such identifiers always appear in citations; whether or not they might include spaces, numbers, or other characters; and what the full set of possible identifiers looks like.
This one has me completely stumped, so I would be mailing friends who might know something about Canadian law.
The answers would be obvious to a Canadian lawyer, of course, and with a bit of effort I could look up the details. But multiplied across the jurisdictions of the world, that is an effort that would prove fatal to the task. A meta tag containing a full formatted citation is better than nothing, but with fine-grained metadata and simple descriptive variable names for each of the elements, the code would practically write itself. It really does make all the difference.
A further issue concerns parallel references, which I mention here for the sake of completeness in ranting. In a world that offers an API to the entire fictional economy of Farmville, one would think that the various and sundry parallel citations to, say, Quackenbush v. US would be available as a simple machine-readable graph. But as we have seen, the leading paywalled providers don't even supply the date of the decision in structured form, let alone parallel citation mappings: the data they publish is basically useless for this purpose.
The least-painful path at present is to visit Google Scholar with Zotero, and fetch the case from the hit listing (not from the case page itself). This yields a set of three cross-linked items that reflect the parallel reports of the case. One click and you're away — but consider what happens behind the scenes: (1) the Zotero translator performs contorted screen-scraping of (2) the displayed citations in the Google listing, which (3) were in turn reverse-engineered from scanned source, and hence (4) cannot be trusted for 100% accuracy. It is a testament to human ingenuity that this is possible at all, but the underlying infrastructure is an embarrassing bundle of wet string.
Parallel references are tracked internally, of course, by the major service providers. Lack of user-side access to these mappings has the side effect (bizarre, from the standpoint of other fields) of placing uncommon importance on human-readable citations, because they are the only available means of identifying a given case across multiple data silos. Given current publishing arrangements, the problem is intractable, and for the present the best we can do on the reference management side is to provide means of recording these relations in personal libraries when they are identified by individual users.
In lieu of concluding
To end on a positive note, compliments are due to the growing number of publishers and dissemination initiatives that have gone the distance to expose well-structured metadata. In the CitationStyles.org project, my own immediate aim is to get the CSL output story into shape, and I confess that I have not followed recent (and some not-so-recent) developments as closely as I should. As styles firm up and field assignment conventions come to be settled, I'll be looking forward to work (by others, as well as a bit myself) on serving the growing number of open-access legal publishers that provide structured metadata.
Zotero is a flexible feeder, and the specific format in which metadata is presented is less important than that it be separated into discrete fields. The meta field assignments in the Cornell LII Supreme Court judgments (CASENAME, DOCKET, DECDATE) serve the purpose. The BibTeX source served by Google Scholar works as well. The legislative metadata at legislation.gov.uk also works. The microformats metadata embedded in Federal cases on law.resource.org gives us enough to work with, and the very complete details in the RECOP material are quite useful when they are carried through in refactored pages (as they are in the Free Law Reporter served by CALI).
One of the benefits to be anticipated, as we make our way toward improved interoperation between publishers and third-party reference management tools for law, is a reduction in the barriers to collaboration between law and other disciplines. Legal citation conventions are by nature quite demanding, and removing some of their sting will improve access not only to the law itself, but also to participation in its discourse.
All signs of rain, and very welcome for grassroots projects like CSL.
Frank Bennett is Associate Professor in the Graduate School of Law at Nagoya University. His active projects related to legal informatics include the citeproc-js CSL processor, an experimental multilingual branch of the Zotero reference manager (MLZ), and the CitationStylist.org initiative for creating a CSL family of legal styles.
The CSL language was originally conceived by Bruce D'Arcus. The CSL 1.0 schema and specification are maintained by Bruce D'Arcus and Rintze Zelle.
(Readers should kindly note that despite Frank's tasteful choice of hat in the photo to the left, the views expressed in this post are his own, and do not necessarily reflect those of Cornell University or the Cornell Legal Information Institute.)
VoxPopuLII is edited by Judith Pratt. Editor-in-Chief is Robert Richards, to whom queries should be directed. The statements above are not legal advice or legal representation. If you require legal advice, consult a lawyer. Find a lawyer in the Cornell LII Lawyer Directory.
Posted by Bennett Frank at 9:38 am Tagged with: Bluebook, Citation of legal authorities, Citation Style Language, CitationStylist.org, citeproc-js, Frank Bennett, Legal Bluebook, Legal citation management software, Legal citation management systems, Legal citation software, Public access to legal metadata, Zotero
Universal Citation for State Codes
Competition in legal publishing, Digital legal publishing, Disruptive legal technology, free access to law, Innovation in legal technology, Legal citation, Legal citations, Public access to legal information 8 Responses »
Source: AALL Universal Citation Guide (First Edition).
In his recent post, Fastcase CEO Ed Walters called on American states to tear down the copyright paywall for statutes. States that assert copyright over public laws limit their citizens' access to such laws and impede a free and educated society. Convincing states (and publishers) to surrender these claims, however, is going to take some time.
A parallel problem involves The Bluebook and the courts that endorse it as a citation authority. By requiring parties to cite to an official published version of a statutory code, the courts are effectively restricting participants in the legal research market. Nowhere is this more evident than in those states where the government has delegated the publishing of the official code to a private publisher, as is the situation in more than half of the states. Thus, even if the state itself or another company, such as Justia, publishes the law online for free, a brief cannot cite to these versions of the code.
To remedy this problem, we (and others) propose applying a system of vendor neutral (universal) citation to all primary legal source material, starting with the state codes. Assigning a universal, uniform identifier for state codes will make them easier to find, use, and cite. While we do not expect an immediate endorsement from The Bluebook, we hope that once these citations find their way into the stream of information, people will use them and states will take notice. We think it's time to bring disruptive technology to bear on the legal information industry.
About Universal Citation
"Universal citation" refers to a non-proprietary legal citation that is applied the instant a document is created. "Universal citation" is also called a "vendor-neutral," "media-neutral," or "public domain" citation. Universal citation has been adopted by sixteen U.S. states in order to cite caselaw, but universal citation has not yet been applied to statutes by any state. A review of universal citation processes for caselaw is helpful in understanding how we may apply universal citation to statutes.
Briefly, a case follows this process before appearing as an official reported decision:
When issuing a written decision, a court first releases a draft called a slip opinion, which is often posted on the court's Website. Private publishers then republish the slip opinion in various legal databases. A party can cite the slip opinion using a variety of citation formats, depending on the database.
Afterwards, the court transmits the slip opinion to the jurisdiction's Reporter of Decisions, who may be a member of the judicial system or a private company. The Reporter edits the opinions, and then collects and reprints them in a bound volume with a citation. To cite a particular page within a case, which is also referred to as pinpoint citation, a party cites the case name, the publication, the volume, and the specific page number that contains the cited content.
Before the advent of electronic publishing, these books were the primary source for legal research. And, while publishers still print cases in book format, the majority of users read the cases in digital form. However, opinions in online database lack physical pages. To address this, online publishers insert page numbers into the digital version of an opinion to correspond to page breaks in the print version. Thus, the pinpoint citation (or star pagination) for an opinion, whether in print or online, is the same.
Under most court rules, and Bluebook guidance, once the official opinion is published, the Reporter citation must be used (see Bluebook Rule 10.3.1).
The decisions are published by a private company, usually Thomson West, and anyone wanting to read them must license the material from the company. Thus, if you want to cite to judicial law, you must pay to access the Reporter's opinions. (Public law libraries offer books and database access, but readers must visit the physical library to use their resources. Google Scholar also provides free access to official cases online, but they must pay to obtain and license the opinions. In other words, Google, not the end user, is paying for the access.)
Universal citation bypasses the private publisher, and allows courts to create official opinions immediately. Under this system, judges assign a citation to the case when they release it. They insert paragraph numbers into the body of the opinion to allow pinpoint citation. This way, the case is instantly citeable. There is no intermediary lag time between slip and official opinion where different publishers cite the case differently, and there is no need to license proprietary databases in order to read and cite the work. In the jurisdictions that have adopted this system, the court's opinion is the final, official version. Private publishers may republish and add their own parallel citations, but in most jurisdictions the court does not require citation to private publishers' versions. (However, Louisiana and Montana require parallel citation to the regional reporter.)
The American Association of Law Libraries (AALL) developed the initial standards for vendor neutral citation formats. AALL published the Universal Citation Guide in 1999, and released an updated edition in 2004. The Bluebook adopted a similar scheme in Rule 10.3.3 – Public Domain Format. Under this format, a universal citation should include the following:
Year of decision
State's 2-letter postal code
Court name abbreviation
Sequential number of the decision
"U" for unpublished cases
Pinpoint citation should reference the paragraph number, instead of the page number
The majority of states employing universal citation follow the AALL/Bluebook standard, but a few have adopted their own styles. (Illinois, Louisiana, Mississippi, New Mexico, and Ohio employ universal citation but use a different format than the AALL/Bluebook recommendation.)
Most states that use universal citation adopted it in the 1990s. Cornell Law Professor Peter Martin details these events in his article Neutral Citation, Court Websites, and Access to Authoritative Caselaw. Professor Ian Gallacher of Albany Law School has also written about the history of this movement in Cite Unseen: How Neutral Citation and Americas Law Schools Can Cure Our Strange Devotion to Bibliographical Orthodoxy and the Constriction of Open and Equal Access to the Law. To date, 16 states assign universal citations to their highest court opinions. (To date, Arkansas, Illinois, Louisiana, Maine, Mississippi, Montana, New Mexico, North Carolina, North Dakota, Ohio, Oklahoma, South Dakota, Utah, Vermont, Wisconsin, and Wyoming have adopted universal citation for caselaw.) Illinois is the most recent state to adopt the measure (in June 2011), and the concept has been gaining traction in the legal blogosphere. John Joergensen at Rutgers-Camden School of Law started a cooperative effort called UniversalCitation.org this summer.
Universal Citation and State Codes
Applying universal citation to state statutes can provide the same benefits as to caselaw, making statutes easier to find and cite, and improving access. While all states publish some form of their laws online for the public, as Ed has noted, these versions of state laws are often burdened by copyright and licensing restrictions. With these restrictions in place, users are not free to reuse, remix, or republish law, resulting in stifled innovation and external costs associated with using poorly designed Websites that take longer to search.
Though the AALL provides guidance on universal citation for statutes, no state has adopted it. The Bluebook does not specifically reference universal forms of citations for statutes and generally requires citation to official code compilations. There are exceptions for the digital version of the official code, parallel citations to other sources, and the use of unofficial sources where they are the only available source. (Bluebook Rule 12 provides for citation to statutes, generally. The Bluebook addresses Internet sources in Rule 18.)
The AALL's Universal Citation Guide provides a schema for citing statutes in a neutral format. Rules 305-307 lay out standardized code designations, numbering, and dating rules, and each state has a full description in the Appendices. Basically, the format uses the state postal code, abbreviations for the name of the statutes (Consolidated, Revised, etc.), and a date.
As a result, the universal citations look similar to the official citations.
The AALL universal citation uses a name abbreviation for the state name and the name of the statute compilation. AALL's format does not use periods in the abbreviations. It also uses a different convention for the year. The Guide's recommendation is to date the code by a "legislative event," to make the date more precise. Using "current through" dating provides a timestamp for the version of the code being used. This approach is less ambiguous than listing simply the year.
States like California and Texas have very large, segmented code systems with more complicated official citation schemes. The AALL mirrors these with the universal version, giving each subject matter code an abbreviation similar to the one used by The Bluebook.
Universal citation does not designate whether the code version is annotated, and of course it does not mention the publisher of the source.
Experimenting with Universal Citation
Justia is now applying the AALL's universal citation to the code compilations on our site. We add this citation to the most granular instance of the code citation, along with a statement identifying and explaining it. So far, we've added citations to the state codes of Hawaii, Idaho, Maine, and South Dakota.
We started with Hawaii. The official citation and the universal citation are fairly similar:
Official: Haw. Rev. Stat. § 5-9 (2010)
Universal: HI Rev Stat § x-x (2010 Reg Sess)
This is how the code looks on the Hawaii Legislature's site:
This is how the code section looks on Justia. We added the citation right above the text of the statute.
On our site, the full citation is visible, so readers can quickly identify and cite to it. The "What's This?" link next to the citation explains the universal citation.
We used the Legislature's site to determine the date.
We also added the universal citation to the title tags. This allows search engine users to see the universal citation in their search results. It makes the search results more readable, because the text of the statute name appears next to the citation. For example, compare a search for "Haw Rev Stat 5-9"
with "HI Rev Stat 5-9":
With the search results for the universal citation (properly tagged), more information about that citation is presented. This helps the user quickly identify and digest the best search results.
We hope to accomplish three objectives by attaching universal citations to our codes. First, we want to give people an easy way to cite the code without having to look at proprietary publications. Not all citation goes into legal briefs or other documents that require formal citation to "official" sources listed by The Bluebook. The AALL universal citation scheme is easy to read and understand, and uses familiar abbreviations (like postal codes). Providing a citation right on the page of the code section will help people talk about, use, and cite to code sections without having to access "official" sources behind a paywall.
Second, we hope to demonstrate that universal citation can be applied in an easy and straightforward manner. The AALL has already developed a rigorous standard for universal citation; we are happy to use it and not reinvent the wheel. Legal folks here at Justia researched the AALL citation and the proper year/date information, and programmers applied the citation to the corpus. Anyone can do this, including the states.
Third, we want to encourage the adoption and widespread use of vendor-neutral citation schemes. There's been a lot of talk about vendor-neutral citation for caselaw, and we are excited by efforts like UniversalCitation.org. Applying these principles to state codes will help get universal citation into the stream of legal information online. Just seeing the citation and the "What's This?" page next to it will introduce readers to the concept. The more people use universal citations for state statutes, the more states will be forced to examine their reliance on third party publishers as the "official" source.
We plan to apply the universal citation to all of the codes in our corpus, but we have encountered some obstacles to achieving this for all 50 states. First, some of the codes are quite large and difficult to parse. Ari Hershowitz has documented his efforts to convert the California code into usable HTML. States like California, Texas, and New York will be more labor intensive. Second, the currency, or timestamp, is not always readily apparent on the state code site. With Idaho, I had to make a call to the Legislative Office to find out exactly when they last updated the code.
The third, and perhaps most troubling, issue is the "unofficial" status of the online state code repositories. With the exception of a few states (see Colorado), the codes hosted on the states' own Websites are papered over with disclaimers about their authenticity. While I understand the preference for "official" sources when citing a code, there seems to be no good reason why the official statutes of any state are not available online, for free, for everyone. These are the laws we must obey and to which we are held accountable. Does the public really deserve something less than official version? The states are passing the buck by disclaiming all responsibility for publishing their own laws, and relying on third-party publishers, which charge taxpayers to view the laws that the taxpayers paid for. I hope that as we apply a universal citation to our state statutes, the law will become more usable for the public. By taking disruptive action and applying these rules to our large corpus of data, we hope that more people will see the statutes and cite using universal principles, and that the states will take notice.
We have assigned a universal citation to the first few states as a proof of concept. We will also be sharing our efforts by supplying copies of the code with the universal citations included for bulk download at public.resource.org. As we move forward with the remaining 46 states, we would love your input. Comment here or contact me directly with your thoughts.
Peace and Onward.
[Editor's Note: For other VoxPopuLII posts on universal citation and the status of content in legal repositories, see Ivan Mokanov's post on the Canadian neutral citation standard, and John Joergensen's post on authentication of digital legal repositories.]
Courtney Minick is an attorney and product manager at Justia, where she works on free law and open access initiatives. She can be found pushing her agenda at the Justia Law, Technology, and Legal Marketing Blog and on Twitter: @caminick.
Posted by Minick Courtney at 7:51 am Tagged with: Courtney Minick, Justia
Time to Turn the Page on Print Legal Information
authentication, digital law, Legal citation, Legal citations, Public access to legal information 15 Responses »
Question: Is there a good reason why judges should not be blogging their opinions?
Follow my thinking here.
I, like many librarians, love books. By that I mean I love physical books. I love the feel of paper in my hand. I love the smell of books. When I attended library school, there was no doubt in my mind that I would work in a place surrounded by shelf after shelf of beautiful books. I was confident that I would be able to transfer that love of books to a new generation.
That's not how things turned out. Without recounting exactly how I got here, I should say that I am a technology librarian, and have been since even before I graduated library school. Technology is where I found my calling, and where libraries seem to need the most help. As I delve deeper into the world of library technology, particularly in the academic setting, I am increasingly forced to confront an uncomfortable reality: Print formats are inferior to electronic. And in some of my darker moments, I may even go so far as to echo the comments of Jeff Jarvis in his book "What Would Google Do" when he writes: "print sucks."
On page 71, talking about the burden of physical "stuff," Jarvis writes:
"It's expensive to produce content for print, expensive to manufacture, and expensive to deliver. Print limits your space and your ability to give readers all they want. It restricts your timing and the ability to keep readers up-to-the-minute. Print is already stale when it's fresh. It is one-size-fits-all and can't be adapted to the needs of each customer. It comes with no ability to click for more. It can't be searched or forwarded. It has no archive. It kills trees. It uses energy. And you really should recycle it, though that's just a pain. Print sucks. Stuff sucks."
In this paragraph, Jarvis may as well have been talking about the current state of online legal information. Although we may not have figured out the magic bullets of authenticity and preservation, the fact remains that print is a burden. In many cases, it is a burden to our governments, and our libraries.
There are good reasons to proceed cautiously towards online legal information. However, the most significant barriers to accepting new modes of publishing official legal information online, like judges' blogging opinions, may be cultural and political. In the end, law librarians and other legal professionals can't allow our own nostalgia and habit to stand in the way of changes that can, should, and must happen.
AALL Working Groups
As many readers may know, the American Association of Law Libraries (AALL) began forming state working groups earlier this year. The purpose of those working groups was to "help AALL ensure access to electronic legal information in your state." This is certainly a worthwhile goal, and one I obviously support. But the PDF document online, calling for formation of these working groups, sends a mixed message.
The very first duty of each working group is to "take action to oppose any plan in your state to eliminate an official print legal resource in favor of online-only unless the electronic version is digitally authenticated and will be preserved for permanent public access, or to charge fees to access legal information electronically. This is an increasingly common problem as states respond to severe budget cuts."
Perhaps it's just the phrasing of the document that bothered me. Rather than even providing guidance to states planning to eliminate print legal resources, AALL has set as its default position the opposition to any such plan.
In fairness, I note that the document hints that online-only legal resources might be acceptable if states don't charge for them, or if such resources meet the rather complex standards laid out in the Association of Reporters of Judicial Decisions' Statement of Principles.
The Association of Reporters of Judicial Decisions (ARJD) published Statement of Principles: "Official" On-Line Documents in February 2007, revised in May 2008. Most tellingly, in Principle 3 of the Statement they write: "Print publication, because of its reliability, is the preferred medium for government documents at present."
Later in the document we find out why print is so reliable. Talking about electronic versions, the ARJD says they should not be considered official unless they are "permanent in that they are impervious to corruption by natural disaster, technological obsolescence, and similar factors and their digitized form can be readily translated into each successive electronic medium used to publish them."
Without question, electronic material must be able to survive a natural disaster. The practice of storing information on a single server or keeping all backups in the same facility could be problematic. But emerging trends and best practices could help safeguard against these problems. In addition, programs like LOCKSS (Lots of Copies Keep Stuff Safe) can help alleviate some of these concerns by making sure many copies of each digital item exist at multiple geographic locations.
Also, digital format obsolescence has largely been overstated. PDF documents are not going anywhere anytime soon. Even conservative estimates establish PDF as a reliable format for the foreseeable future.
HTML may be no different. Consider that the very first Web document, Links and Anchors, is almost valid HTML5. Nearly 20 years later, that document is compatible with modern Web browsers.
On the other side of the equation, is print impervious to natural disaster, or even technological obsolescence? Of course not. At Yale, with our rare books library and large historical collection, I have witnessed first hand the damage time can do to a physical book. Even more importantly, books in the last hundred years have been published so cheaply they may fall apart even sooner than books published centuries ago.
Print and Electronic Costs
The reality is that moving to online-only legal information is a good thing for everyone involved in producing and consuming such information. The burden of print is not limited to the costs forced upon states that produce it; that burden is also borne by libraries and citizens who consume it.
As mentioned above respecting the AALL working group document, many states are already looking at going online-only to cut costs, and why shouldn't they? With current budget situations across the country being what they are, printing costs being particularly high, and electronic publishing costs being so low, of course states are looking at saving money by ending needless printing.
But libraries would also benefit from the cost savings of governments' moving to electronic formats. Not only do libraries currently have to subsidize printing costs by paying for the "official" print copies of legal materials; libraries also have to pay for the shelf space, as well as manpower to process incoming material and place it on the shelf, and may also have to pay additional costs for preserving the physical material. Not to mention the fact that we may pay for additional services that furnish access to the exact same material in an electronic format.
The costs involved in dealing with print legal resources are well known to most librarians. So why aren't we clamoring for governments to publish online-only legal information?
Officialness, Authenticity, Preservation, and Citeability
Of course there are genuine concerns about online-only legal information. The big sticking points seem to be (in no particular order) officialness, authenticity, preservation, and citeability. Each issue is worthy of, and has been the subject of, much discussion.
Officiality may be in some ways the easiest and most difficult hurdle for online-only legal information to leap. To make an online version of legal material official, an appropriate authoritative body need only declare that version "official." The task seems simple enough.
The more difficult part may be political. With organizations like AALL and ARJD currently opposing online-only options, that action may be politically difficult. Persuading lawyers, judges, and legislatures to approve such a declaration could be even more difficult. Can you imagine a bill, regulation, or some other action making a blog the "official" outlet for a particular court's opinions?
The question of authenticity is more difficult to deal with from a technological perspective, although there has been interesting work done with respect to PDFs, electronic signatures, and public and private keys. The Government Printing Office (GPO) has done a great job leading the way in the area of authenticity: http://www.gpoaccess.gov/authentication/. The new Legislation.gov.uk site unveiled recently has taken a different approach from the GPO's. As John Sheridan has written in an earlier post, at the moment The U.K. National Archives are not taking any steps towards authenticating the information on the Legislation.gov.uk site, but they recognize the need to address the issue at some point. John Joergensen at Rutgers-Camden has taken yet another approach. And Claire Germain, in a recent paper about authentication practices respecting international legal information (pdf), states that those practices vary throughout the world. Thus the prickly question of authenticating online legal information is an issue that's not going away any time soon.
AALL and ARJD have made a big deal about preservation of online legal information, an issue that's important for librarians, too. Unfortunately, this is another area where no good answer exists to guide us. As Sarah Rhodes wrote earlier this year, "our current digital preservation strategies and systems are imperfect – and they most likely will never be perfected."
The Library of Congress National Digital Information Infrastructure & Preservation Program (NDIIPP) has some helpful resources. The Legal Information Preservation Alliance (LIPA) also provides some good guidance in this area. However, many librarians are still reluctant to accept that digital preservation practices may enable us to end our reliance on print.
A similar reluctance can be seen in resistance to the Durham Statement, which — though directed at law reviews — also says something about other kinds of online legal information. Most notably, Margaret Leary of the University of Michigan chose not to sign the Durham Statement, and discussed her decision to continue to rely on print at a recent AALL program. In a listserv posting quoted in Richard Danner's recent paper, Ms. Leary asserted: "I do not agree with the call to stop publishing in print, nor do I think we have now or will have in the foreseeable future the requisite 'stable, open, digital formats'." Similarly, Richard Leiter explains that he signed the Durham Statement with an asterisk because of the statement's call for an end to the printing of law reviews.
What constitutes 'stable, open, digital formats' for the purposes of satisfying some librarians is unclear. As I mentioned earlier, a number of digital formats currently fit this description. This makes me think that there's something else going on here, a resistance to abandoning print for other reasons.
Citeability also becomes an issue as print legal information disappears. If there is no print reporter volume in which an opinion is issued, then how would one cite to an opinion (setting aside for a moment Lexis and Westlaw citations)?
However, efforts towards implementing "medium-neutral legal citation formats" have already been made. According to Ivan Mokanov's recent VoxPopuLII post, most citations in Canada are of a neutral format. In the United States, LegisLink.org has made an effort to improve online citations, as Joe Carmel describes in his recent post. Work on URN:LEX and other standards has resulted in some progress towards dealing with the citeability issue. Organizations like the AALL Electronic Legal Information Access & Citation Committee also deserve credit for taking this on. [Editor's Note: Those organizations have produced universal citation standards — such as the AALL Universal Citation Guide — which have been adopted by a number of U.S. jurisdictions.] Even The Bluebook supports alternative citation formats. For example, rule 10.3.3, "Public Domain Format," specifies how to cite to a public domain or "medium-neutral format." The Bluebook even goes so far as to allow citation in a jurisdiction's specified format.
But despite all this work, nothing has yet stuck.
One thing you'll notice respecting all of these issues is that they are currently unsettled. While AALL and ARJD have both suggested that they would look favorably on online-only legal information if it were official, authenticated, and preserved (they do not mention citeability), there is no indication of when we will reach a level of achievement on these issues that would be satisfactory to these organizations. Can governments, libraries, and citizens afford to wait?
Asking states to continue to bear the burden of publishing material in print as they run out of funding, and libraries to bear the expense of preserving that print, is irresponsible. While we might not have all of the answers now, we certainly have enough to move forward in an intelligent manner.
The National Conference of Commissioners on Uniform State Laws (NCCUSL) has been working on an Authentication and Preservation of State Electronic Legal Materials Act. [Editor's Note: The Chair of the Act's Drafting Committee is Michele L. Timmons, the Revisor of Statutes for the State of Minnesota, and its Reporter is Professor Barbara Bintliff of the University of Texas School of Law.] According to the Study Committee's Report and Recommendations for the Act's Drafting Committee, the goal of the draft should be to "describ[e] minimum standards for the authentication and preservation of online state legal materials." This seems like an appropriate place to start.
Rather than setting unrealistic or vague expectations, the minimum standards provided by the draft act seem to allow some flexibility for how states could address some of these issues. As opposed to working towards a "stable and open digital format," which seems more a moving target than an attainable goal, the draft act sets forth an outline for how states can get started with publishing official and authentic online-only legal information. While far from finished, the draft act appears to be a step in the right direction.
What Is the Real Issue?
I think the real sticking point on this matter is mental or emotional. It comes from an uneasiness about how to deal with new methods of publishing legal information. For hundreds of years, legal information has been based in print. Even information available on the Lexis and Westlaw online services has its roots in print, if not full print versions of the same material. It's as if the lack of a print or print-like version will cause librarians to lose the compass that helps us navigate the complex legal information landscape.
Of course, publishing legal information electronically brings its own challenges and costs for libraries. Electronic memory and space are not free, and setting up the IT infrastructure to consume, make available, and preserve digital materials can be costly. But in the long run, dealing with electronic material can and will be much easier and less costly for all involved, as well as giving greater access to legal information to the citizens who need it.
So Judges Blogging?
Although he was the co-chair of the ARJD committee that produced the Statement of Principles, even Frank Wagner, the outgoing U.S. Supreme Court reporter of decisions, acknowledges that "budgetary constraints may eventually force most governmental units to abandon the printed word in favor of publishing their official materials exclusively online." He also recognizes that the GPO's work in this area may put an end to the printed U.S. Reports sooner than other "official publications."
So were an appropriate authority to make them official, and some form of authentication were decided on, and methods of preservation and citation had been taken into account, would you feel comfortable with judges' blogging their opinions?
We have to get over our unease with new formats for publishing online legal information. We have to stop handcuffing governments and libraries by placing unrealistic and unattainable expectations on them for publishing online legal information. We have to prepare ourselves for a world where online is the only outlet for official legal information.
I still enjoy taking a book off the shelf and reading. I enjoy flipping through and browsing the pages. But nostalgia and habit are not valid strategies for libraries of the future.
Jason Eiseman is the Librarian for Emerging Technologies at Yale Law School. He has experience in academic and law firm libraries working with intranets, websites, and technology training.
VoxPopuLII is edited by Judith Pratt. Editor in chief is Robert Richards.
Posted by Eiseman Jason at 10:16 am Tagged with: Authentication of digital legal information, Authentication of electronic legal information, Authentication of legal information, Court opinions, Digital legal publishing, Durham Statement on Open Access to Legal Scholarship, Electronic legal publishing, Jason Eiseman, Judicial information systems, Judicial opinions, Legal publishing, Legal scholarship, Open access to legal scholarship, Preservation of digital legal information, Preservation of electronic legal information
Environmentally-Friendly Citations
commercial systems, Legal citation, Legal citations, Legal descriptive metadata, Legal informatics, Legal knowledge representation, Legal metadata, legal research, Standards 9 Responses »
Today in Canada, nearly three quarters of citations to recent case law use the neutral citation – an industry-independent, open identifier assigned by courts to their decisions. When we call something a "game-changer" most people assume that it was invented by Apple. Yet even though the neutral citation was not, it definitely is a game-changer in the legal publishing business. Here are some thoughts about why.
Cited and Citing Cases
Legal publishing would be much simpler if cases did not cite other cases or all sorts of other legal documents. However, in that event the law would be far less intelligible. The citations between legal documents help establish a coherent body of law. The interpretation of cases and statutes in their surrounding context of citing and cited legal documents is crucial in legal practice. It is often considered prudent to wait until the courts have their say on a freshly enacted statute before relying blindly on it. And no lawyer would bring up a "dynamite" case in court before carefully checking to see how this case has been treated by other case law.
Indeed, all legal publishers try in various ways to exploit the relations between legal documents in order to stand out in the eyes of their customers. Many features of the electronic publishing systems are based in some way on the relations between documents – hyperlinking, note-up, lists of cases and statutes considered, related cases, judicial history and treatment, search results ranking based on popularity, etc. The use of citation data has defined legal publishing for many years. Any major change in how things are cited in law will continue to have a great impact on legal publishing in the future.
Originally, citation data was neither intended nor designed to yield itself easily to computer processing, let alone free online publishing.
The Chinese Walls Around Print Report Series
The problem is well known. Print report citations were not designed to function outside the context of the report series they belong to. For example, "301 D.L.R. (4th) 513" does not mean anything to you if you don't have the Dominion Law Reports nearby. Even if you were lucky enough to have the series in your firm's library, you could not safely cite a case by, for example, 301 D.L.R. (4th) 513 and expect all your readers to understand what you are saying unless you assume that all your readers have the Dominion Law Reports in their libraries. This issue is amplified by the number of print law reports. In Canada, there are 70 major law report series according to the Queen's University Law Library. (Although some from the list may have disappeared since the list was last updated, the number of report series remains large.)
To cope with this reality, the legal publishing world came up with citators, and in particular, their ability to offer and make use of parallel citations. Citators can tell you, among other things, what possible identifiers (citations) have been assigned to a particular case. For example, the following list – [2009] 1 S.C.R. 181; 301 D.L.R. (4th) 513; [2009] 2 W.W.R. 385; 183 C.R.R. (2d) 1; 320 Sask. R. 305 – means that the case Ravndahl v. Saskatchewan can possibly be identified by any the citations included in the list.
Commercial Electronic Databases Are Not Better
Nobody will dispute the fact that, for all practical purposes, electronic sources are the research tool. Printed reports will wither and gradually disappear. Those that remain because of their official status will be used, not for research, but only as the recognized source of citable law. Many if not most legal researchers will even affirm that this is already the de facto situation.
It is worthwhile to analyze what will happen in that new electronic context. Citations will be based on database identifiers. In Canada, such citations will take the following form: "[1998] O.J. No. 2515 (QL)". In some ways, such a citation is leading to the same old problems discussed earlier in this post: those of proprietary citations. However, if the inconvenience of having to check in a specific book to know what was cited was annoying, citations consisting of commercial database identifiers create a much more serious problem. To get the cited material, whereas in the print environment the researchers had to take the time to visit the library, in the digital environment they must subscribe to the commercial database. In the era of the Internet, any type of proprietary citations could seriously threaten the legal information system.
The Free Law Publisher's Initial Approach
One way of dealing with Chinese Walls is to live with them, and use one's wits to figure out what is on the other side.
In 2004, CanLII was striving to be recognized as a legal information product that could successfully serve the everyday research needs of legal professionals. The idea emerged to develop a citator in order to improve hyperlinking — and a series of other cool features — using the relations between legal documents.
Building a citator is an expensive operation. Here is a brief outline of the manual and automated methodology mix that was employed to build Reflex, CanLII's citator.
0. It all starts in a law library.
1. An editor keys in information about all cases published in a particular report series, for example, the Dominion Law Reports. Such information includes the case name, the docket number, the issuing court, the date of the decision, a very short excerpt from the case, and the report citation.
2. This operation results in many records like the following one:
Case name: Ravndahl v. Saskatchewan
Docket: 32225
Court: SCC
Excerpt: The appellant lost…
Citation: 301 D.L.R. (4th) 513
3. Another editor keys in the same information about all cases published in another report series, for example, the Western Weekly Reports, producing records like this one:
Citation: [2009] 2 W.W.R. 385
4. A program examines all the records and concludes that if all metadata is identical among pairs of records, the two independently compiled records must pertain to the same case, thus 301 D.L.R. (4th) 513 and [2009] 2 W.W.R. 385 are parallel citations of the same judgment.
5. The operation is repeated for 35 report series on an ongoing basis.
Of course, in practice the exercise is much more complicated, as the software has to deal with various degrees of similarities of metadata; for example, almost identical case names (R. v. Smith and The Queen v. Smith). The program can also encounter other misfortunes, such as the absence of docket numbers or dates.
With this approach, CanLII was able to expand significantly the breadth of hyperlinking within legal documents, and all features based on the hypertext, such as sorting search results by number of citations, providing lists of related cases, and a few more. Because Reflex is able to resolve citations to cases that are unavailable on CanLII, the number of citations was used also as an indicator as to what are the most important cases missing from CanLII, or, in other words, where to start from if we want to scan cases from paper and publish them on CanLII.
As one of the founding members of the free-access-to-law movement, CanLII may have revolutionized the way Canadian law was made accessible, but the print was still a ubiquitous part of our publishing routine.
Another Way of Dealing With the Chinese Walls…
… is to simply destroy them. Before CanLII's arrival on the legal information playground, LexUM, in collaboration with representatives from the judiciary, law librarians, court staff, IT consultants, and several forward-looking individuals from the commercial publishing circles, had set up the Canadian Citation Committee. The CCC is an ad hoc group formed to support the standardization efforts of the Judges Technology Advisory Committee (JTAC) of the Canadian Judicial Council (CJC).
The CCC designed and promotes several documentary standards, among them the neutral citation. The neutral citation was proposed as a unique, industry-independent identifier, assigned to a case by the court. It is formed in a simple way: by the year of the case, an acronym for the issuing court, and a serial number. For example, 2009 SCC 7 designates the case of the Supreme Court of Canada Ravndahl v. Saskatchewan, released in 2009.
Simple, open, Internet-friendly, environmentally-caring, promising: such is the neutral citation.
Who's on Board?
Courts have gradually been adopting the neutral citation, beginning in 1999 and continuing to the present. The first adopter of the neutral citation was the Superior Courts of British Columbia. Today, all 50 Canadian courts follow the neutral citation standard. The last one to join — just this year, in fact — was the Ontario Superior Court of Justice – the toughest jurisdiction in the country (from a judicial administration and legal publishing point of view) because of the complexity of its judicial structure. As a result, all 50,000 cases issued annually by Canadian appellate, superior, and trial courts now bear neutral citations that have been assigned by the courts. To that number, we must add the decisions rendered by at least two dozen administrative tribunals which have also adopted the standard.
Probably a more important question than "Who's on board?" is: Why are those institutions on board? Before embracing a change, people often need at least one ideological reason and at least one practical reason. On philosophical (and economic) grounds, it certainly made sense for court decisions to be freed from proprietary citation schemes. From a practical point of view, the most convincing argument was the convenience for the court to have a unique designation of its own decision at the very moment the reasons of the decision are issued.
Are Lawyers and Judges Following?
If you read carefully the first paragraph of this post, you know that the answer is yes. Lawyers and judges do cite cases using the neutral citation. They use neutral citations much more frequently than one may think.
Let's bring in some data. On CanLII, case citations are hyperlinked if the citation comes from one of the 35 reports covered by CanLII's citator or if the citation is a neutral citation. This allows for a citation resolution success rate of about 80%. This means that 80% of case citations on CanLII are hyperlinked. The rest, many of which are citations to proprietary commercial databases, are not.
In this context, it was tempting to verify the portion of the links attributable to the neutral citation. Or in other words, what is the percentage of case citations that contain the neutral citation – alone or among other parallel citations?
So we examined two sets of citations. The first one contained 40,000 citations of cases released in 2006, 2007 and 2008. The second one included 41,000 citations of cases released in 2007, 2008 and 2009.
The count showed the following. In data set 1 (citations pointing to cases released in 2006, 2007 and 2008), 85% of hyperlinked citations are, or contain, a neutral citation. In data set 2 (citations to cases released in 2007, 2008 and 2009), the neutral citation accounts for 91% of the links.
Data Set #1
40,000 citations
Citing cases released in 2008
Cited cases released in 2006, 2007, 2008
Links based on neutral citations: 85%
Share of all citations that are or contain neutral citations: 68%
Needless to say, both the numbers and the progression look exciting. This, of course, is not the last reason we need before sending the print reports sailing into history.
It is just one more.
Ivan Mokanov is Deputy Director of LexUM. He oversees LexUM's publishing and development activities and supervises various consulting and research projects in Canada and abroad. As a member of LexUM's Executive Committee, he participates in LexUM's administration and business development. Ivan is a graduate from Sofia University (B.C.L.) and the University of Montreal (LL.M.), and he is currently enrolled at HEC Montreal (M.B.A).
Posted by Mokanov Ivan at 12:11 am Tagged with: CanLII


◊ The bail paid by a person accused of a crime is returned when the person comes back to court for a trial. To set bail is to decide how much money a person must pay in order to get out of jail until a trial.
The judge/court set bail at $1 million. = The bail was set at $1 million.
To grant bail or give bail is to allow a prisoner to pay money to leave jail until a trial.
It is not clear whether the judge will grant bail in this case.
If you are denied bail or held without bail, a court will not allow you to pay money to leave jail until your trial.
The two men are being held without bail.
Bail was denied, and he was sent to prison to await his trial.
If you are free on bail or out on bail or have been released/freed on bail, you have paid the court money and are now out of jail and waiting for your trial.
He is now free on bail. = He's out on bail.
If you make bail or post bail, you give enough money to the court and can leave jail until your trial.
He didn't have enough money to make bail so he had to stay in prison until his trial.
Someone posted bail for you. You're free to go.
To jump bail or skip bail is to pay money to get out of jail and then not return for your trial.
A day after he was released from jail, he decided to jump bail and leave the country.
They skipped bail a week before the trial.
She went to the jail to bail out her boyfriend. = She bailed him out of jail.
They're always bailing their son out of trouble.
The federal government bailed out [=gave money to] their struggling company.
We used a bucket to bail water out of the canoe. = We used a bucket to bail out the canoe.
The pilot bailed out [=(Brit) baled out] just before the plane crashed.
Most investors have bailed out [=(Brit) baled out] of the business.
They bailed out [=backed out] of the deal.
What made you want to look up bail? Include any comments and questions you have about this word.


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"VETERANS FARM AND HOME BONDS"
Assembly Constitutional Amendment No.4. Authorizes issue and sale of four hundred million dollars ($400,000,000) in state bonds to provide funds to be used by State Department of Veterans Affairs in accordance with Veterans Farm and Home Purchase Act of 1943 in assisting California war veterans to acquire farms and homes. Brings into operation and validates Veterans Bond Act of 1960 governing issue, sale and redemption of such bonds.
VETERANS FARM AND HOME BONDS California Proposition 1 (1960).


text:
Q: Collect function with iterator issue I've got the following code for the first few terms of an expansion. I want to collect the terms in increasing powers of (s/r) but using an iterator. The code is as follows:
formula=1-n x + 1/2 n (n+1) x^2-1/6 n (n+1 ) (n+2) x^3 /. {x->((s/r)^2-2 (s/r) Cos[θ]),
        n->1/2};
Expand[%];
Collect[%,{(s/r),(s/r)^2,(s/r)^3,(s/r)^4}]

The output is what I want but how would I do this using a counter or iterator? So something like
Collect[%, {(s/r)^i,{i,0,n}}]

But obviously not that because it doesn't work!

A: Instead of Collect, you can use PolynomialReduce
Flatten@PolynomialReduce[formula, Table[(s/r)^i, {i, n /. n -> 5}], {s, r}][[2]]

A: We can pre-initialize our list of factors with Table:
Collect[Expand[formula], Table[(s/r)^i, {i, 5}]]
should get the job done.
Or, as Bob Hanlon notes, Power is Listable so we can do:
Collect[Expand[formula], (s/r)^Range[5]]

redpajama_set_name: RedPajamaStackExchange


text:
using System.Collections;
using System.Collections.Generic;
using System.Linq;

namespace EFSqlTranslator.Translation.DbObjects
{
    public class DbSelectableCollection : DbObject, IEnumerable<IDbSelectable>, IDistinctable
    {
        private readonly IDbSelect _owner;

        private readonly List<IDbSelectable> _selectables = new List<IDbSelectable>();

        public DbSelectableCollection(IDbSelect owner)
        {
            _owner = owner;
        }

        public bool IsDistinct { get; set; }

        public void Add(IDbSelectable selectable)
        {
            if (_selectables.Contains(selectable))
                return;

            _selectables.Add(selectable);
            selectable.OwnerSelect = _owner;

            if (_owner.GroupBys.Any())
                _owner.GroupBys.Add(selectable);
        }

        public void Remove(IDbSelectable selectable)
        {
            if (!_selectables.Contains(selectable))
                return;

            _selectables.Remove(selectable);
        }

        public void Clear()
        {
            _selectables.Clear();
        }

        public override string ToString()
        {
            var selection = string.Empty;
            if (!_selectables.Any())
            {
                selection = $"{_owner.From.Alias}.*";
            }
            else
            {
                var selections =
                    from s in _selectables
                    select s.ToSelectionString();

                selection = string.Join(", ", selections);
            }

            return IsDistinct ? $"distinct {selection}" : selection;
        }

        public IEnumerator<IDbSelectable> GetEnumerator()
        {
            return _selectables.GetEnumerator();
        }

        IEnumerator IEnumerable.GetEnumerator()
        {
            return ((IEnumerable) _selectables).GetEnumerator();
        }
    }
}

redpajama_set_name: RedPajamaGithub


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text:
Q: Coq/SSReflect: How to do case analysis when reflecting && and /\ I have the following reflect predicate:
Require Import mathcomp.ssreflect.all_ssreflect.

Inductive reflect (P : Prop) (b : bool) : Prop :=
| ReflectT (p : P) (e : b = true)
| ReflectF (np : ~ P) (e :  b = false).

And I am trying to relate the boolean conjunction to the logical one and the following one-line proof goes through:
Lemma andP (b1 b2 : bool) : reflect (b1 /\ b2) (b1 && b2).
Proof.
  case b1; case b2; constructor =>//; by case.
Qed.

However, I don't understand how the last ; by case. is applied. When we examine the proof without the last ; by case.:
Lemma andP (b1 b2 : bool) : reflect (b1 /\ b2) (b1 && b2).
Proof.
  case b1; case b2; constructor =>//.

We get 6 subgoals (2 are trivially true):
6 subgoals (ID 45)

  b1, b2 : bool
  ============================
  true /\ false

subgoal 2 (ID 46) is:
 true && false = true
subgoal 3 (ID 116) is:
 false /\ true
subgoal 4 (ID 117) is:
 false && true = true
subgoal 5 (ID 187) is:
 false /\ false
subgoal 6 (ID 188) is:
 false && false = true

I'm not sure how to proceed from here because they all are false - how can we prove that? I tried doing . case. individually but that doesn't work. How does ; by case admit these subgoals all at once?
Thank you.

A: The behavior of sequential composition for tactics changed a bit in recent years. Nowadays, tactics like constructor can backtrack while executing their continuation.  Because your definition of reflect is a bit different from the standard one, if you just call constructor, Coq will immediately apply ReflectT, leading to a stuck goal in three of the cases:
Lemma andP (b1 b2 : bool) : reflect (b1 /\ b2) (b1 && b2).
Proof.
case b1; case b2=> /=.
- constructor=> //.
- (* constructor. *) (* Stuck *)

When you use sequential composition, the constructor tactic backtracks, correctly finding the ReflectF constructor.
  constructor; by try case.
- constructor; by try case.
- constructor; by try case.
Qed.

A: I'm not sure why you are getting 6 subgoals: case b1; case b2; constructor produces 4 subgoals, corresponding to the four possible cases for combinations of boolean values:
  true /\ true

subgoal 2 (ID 13) is:
 ~ (true /\ false)
subgoal 3 (ID 15) is:
 ~ (false /\ true)
subgoal 4 (ID 17) is:
 ~ (false /\ false)

The first one is considered trivial by //.
Set Printing Coercions will tell you that your subgoals or actually as follows:
  is_true true /\ is_true true

subgoal 2 (ID 13) is:
 ~ (is_true true /\ is_true false)
subgoal 3 (ID 15) is:
 ~ (is_true false /\ is_true true)
subgoal 4 (ID 17) is:
 ~ (is_true false /\ is_true false)

Unfolding is_true might help: case b1; case b2; constructor; rewrite /is_true.:
  true = true /\ true = true

subgoal 2 (ID 19) is:
 ~ (true = true /\ false = true)
subgoal 3 (ID 20) is:
 ~ (false = true /\ true = true)
subgoal 4 (ID 21) is:
 ~ (false = true /\ false = true)

The 3 last subgoal are of the form (_ /\ _) -> False (because ~ P stands for not P, which unfolds to P -> False.
Thus the case tactic added after constructor destructs the top assumptions turning the last three goals into the following:
  true = true -> false = true -> False

subgoal 2 (ID 145) is:
 false = true -> true = true -> False
subgoal 3 (ID 155) is:
 false = true -> false = true -> False

Here, we have false = true as one of the assumptions in each subgoal, meaning we got a contradiction that SSReflect can immediately recognize and finish the proof using the principle of explosion.


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Rick, Shaun, and (later) Alex get together to talk about Jordan Peterson, Ideology, Atomwaffen Division, Fr Seraphim Rose, violence, and Nihilism.


text:
Products (AU) Products (NZ) Newsroom Careers Contact Us Australia New Zealand
About Takeda How can we do more for our patients?
Company Information Company Facts History Worldwide Offices Positions & Guidelines
From the CEO
We have global presence in more than 70 countries.
Our Business Takeda continues its transformation into an agile and innovative global pharmaceutical leader, serving the needs of patients and physicians worldwide. Learn more
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Our Stories A selection of stories related to Innovation, Caring and Heritage Learn more
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HOME Who We Are Company Information History 1781-1944
Company Facts History 1781-1944 1945-1984 1985-1999 2000- Our Corporate Symbols Worldwide Offices Positions & Guidelines
Foundation-Modernization: 1781-1944
1781 Founding
Over two centuries ago in 1781, 32-year-old Chobei Takeda I started a business selling traditional Japanese and Chinese medicines in Doshomachi, Osaka, the center of the medicine trade in Japan. His small shop bought medicines from wholesalers, then divided them into smaller batches and sold them to local medicine merchants and doctors. This was the beginning of the present-day Takeda Pharmaceutical Company Limited.
1852 Chobei III to build a new home
In April 1852, Chobei III demolished the old mansion in the southeast of Doshomachi Nakabashisuji and built a new home and a warehouse. These buildings lasted approximately 75 years until the construction for the head office building started in 1927.
1871 Import of Western medicines begins
Chobei Takeda IV led other medicine retailers in turning his attention to Western medicine. He formed a cooperative union for purchasing Western medicines in Yokohama and began transactions with foreign trading companies. Western medicines imported at the time included quinine, an anti-malaria drug, and phenol, an anti-cholera drug.
Takeda began direct imports from England, the U.S., Germany, Spain and other countries around 1895, and in 1907 obtained exclusive sales rights in Japan for products from German company Bayer. Thus, the business that began as a shop selling old-fashioned Japanese and Chinese remedies steadily increased its selection of Western medicines, before shifting its basic orientation to Western medicine.
1882 Scenery of pharmaceutical stores
"Shokogigei Naniwa no Sakigake"(Kakinuki Yosuke Publication, Osaka, 1882)
1895 Pharmaceutical manufacturing business launched
In 1895, the Company acquired Uchibayashi Drug Works to establish its own factory in Osaka and became a pharmaceutical manufacturer. This factory produced products such as bismuth subgallate (an antidiarrheal agent) and quinine hydrochloride.
1914 Research activities begin with establishment of a research division
Around this time, Takeda began introducing a succession of its own products. Among these were Calmotin®(a sedative), Novoroform®(an analgesic) and Lodinon®(an injectable form of D-glucose). Takeda steadily expanded its pharmaceutical business and even began exports to the U.S., Russia and China.
1915 Takeda Pharmaceutical Company was established
Soon after starting the pharmaceutical business, the testing division was formed. The research division, which researched and developed new pharmaceutical products, was also formed in 1915. The R&D system formed during this period became the foundation which lead to the growth of Takeda.
1920 Takeda Store before the shortening of the eaves
Along with the shortening of the eaves and the widening of the roads in Doshomachi, wooden block pavements were laid.
1920 Takeda Store after the shortening of the eaves
1922 Image of Doshomachi(The company is in the center)
Around 1922(The company on the left corner of Nakabashisuji)
From an image of Kasukabe Kasumimura (drawing of shopping street)
1925 Incorporated as Chobei Takeda & Co., Ltd.
The Company was incorporated as Chobei Takeda & Co., Ltd., with capital of 5.3 million yen and Chobei Takeda V as president. The Company went from being an individually owned business to a modern corporate organization integrating R&D, manufacturing and marketing. The Company changed its name to Takeda Pharmaceutical Industries, Ltd. in 1943 (its English name was changed to Takeda Chemical Industries, Ltd. in 1961).
1925 Bird's-eye view of the factory in 1925
Takeda Pharmaceutical Company merged with Chobei Takeda & Co., Ltd in 1925 and became the main factory of the pharmaceutical division.
1933 Takeda Garden for Medicinal Plant Conservation (Kyoto)* was established
This conservation has collected, grown and used herbs and other plants with medicinal value from around the world. Currently, the garden has more than 2,882 species of plants, including 104 endangered species.
*Established as "Kyoto Takeda Herbal Garden." The name was changed to "Kyoto Experimental Garden" in 1945 and changed again to its current name in 1994.
1944 Institute for Fermentation, Osaka was established
For more than 60 years, this institute has been devoted to the preservation of microorganisms to support research. Today, it serves as a research foundation dedicated to the advancement of microbial science.
Takeda Australia Legal Note TAKEDA PRIVACY NOTICE ACCESSIBILITY STATEMENT
Links to external web sites from this site are offered for your convenience. These websites may provide information on products not available in Australia and may not comply with the Australian regulatory environment. Further information on Takeda products relevant to the Australian environment is available from the company or via the Product Information. While care has been taken to ensure that these external websites provide educational material for the Australian public on related topics, please be aware that Takeda Australia takes no responsibility for the availability or content of these external sites, nor does Takeda Australia endorse, warrant or guarantee the products, services or information described or offered at these other Internet sites. Any information provided by these sources should be discussed with your health care professional and does not replace their advice.

redpajama_set_name: RedPajamaCommonCrawl


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I was gladly surprised by Tunisian cuisine. A good and tasty variety of flavours, combining Mediterranean (mostly French but also Italian) and North African culinary traditions. This fusion and diversity come from the many civilisations which have ruled the land: Romans, Vandals, Byzantines, Arabs, Spanish, Turkish, Italians, French, and the native Punics-Berber people [Wikipedia].
You will notice two distinctive traditions when ordering food in Tunisia: they always give you a lot of bread free of charge, and most of the times a snack/starter as well. Bread is very important in any meal and it is even used to eat as a cutlery replacement.
Probably the most famous and traditional Tunisian dish. Most restaurants and hotels have it on their menu, and some street shops as well.
It is a delicate pastry dough called Malsouka, which is fried and stuffed with egg, parsley and tuna. It is served with lemon and there is a technique to eat it: you take a couple of bites until you are about to reach the egg, and when you are there you need to swallow it, so you don't spill the egg's liquid. You can also keep adding lemon at any time.
Its shape may vary slightly, being normally a triangle (like a folded pizza, calzone or samosa). You can find other fillings as well, such as cheese, potatoes or shrimps. High-quality briks seems to be multi-layered and dryer than the rest.
It is generally served as the second course during Ramadan, which is the main reason behind its popularity.
This is a basic but effective salad, containing tomato, onion, cucumber, beans, potatoes, olives, tuna and egg. It is normally served with olive oil and lemon on top, and sometimes with Harissa as well.
I was having this salad with a local friend and he told me: "this is called Tunisian salad, but there is nothing traditionally Tunisian in it". That being said, I would emphasise its freshness and taste.
This "red" salad is very traditional, and it was the first local dish I was tempted to try when I arrived in Tunis. You will find it in most restaurants and coffee shops.
It is made of grilled sweet red peppers, tomatoes and onions mixed with oil, lemon, tuna fish and hard–boiled eggs. It can be spicy so better to ask first. It can also be served either mild or hot, and sometimes alongside grilled fish or lamb as part of another dish.
This is one of Tunisian's favourite street food, and it was probably mine as well. It is a savoury fried doughnut filled with tuna, boiled egg, olives, harissa, and boiled potato.
There is an open area in La Marsa where we got both the Bambalouni and Fricassé, and also homemade potato crisps. It is next to the main mosque in the area.
La Marsa really has a laid-back Mediterranean vibe and it is where most middle-class Tunisians and ex-pats live. So I would recommend to go and walk your way around.
This was probably my favourite. Not only because it was tasty, but also because it was original and fun in the procedure to get it prepared.
Lablabi is a thick soup or stew made of chick peas and flavoured mostly with cumin and garlic. It is served over small pieces of stale crusty bread, which is recommended to be 2 days old. A soft egg is also added to the soup, along with olive oil, harissa, capers, tuna, olives, lemon juice, garlic and additional cumin.
The preparation was very interesting. You get an empty bowl (clay pot) and a piece of hard bread (2 days old). So first you need to cut the bread into small pieces with your hands and fill the bowl with them. You then hand over this to the cook who will add all the rest of the ingredients and give it back to you. You finally mix everything up using two spoons and that's it, you get your stew ready to eat.
We had it in a very good place in the Du Lac 1 area, called Café-Halfaouine, where you can also have tea, coffee, shisha, and more. Totally recommended.
Probably you all have heard about Couscous or have already tried it at least once. It is a Maghrebi dish of small (about 3mm diameter) steamed balls of crushed durum wheat semolina, usually served with a stew spooned on top [Wikipedia].
There are endless different ways to prepare it, and it can vary in different areas of the country. It is normally served in a deep plate with a piece of meat or fish and some vegetables on top. Preferred meats include lamb or chicken, and fish can vary between red snapper, grouper, sea bass and swordfish. Favoured vegetables include peppers, carrots, pumpkin and potatoes.
Locals seem to agree that Couscous is originally from Morocco. However; its origin is uncertain, and it is considered traditional throughout the North African cuisines of Morocco, Algeria, Tunisia, Mauritania and Libya.
It is a spicy paste made with chilli peppers and garlic, which is often served as a condiment (for meat, fish or salad) or dip. I've had it a few times and it is not as hot as it seems. Most places serve it with bread and olive oil as a snack, being altogether a very tasty combination.
Harissa is a traditional Tunisian product, and quite appropriate for a gift/souvenir. You can get it everywhere, from supermarkets to gift shops, and also at the airport.
Moreover, Harissa is getting trendy in different parts of the World. You can easily find dishes and meals with it in the UK (for instance, M&S offers fish and meat with this paste). Last week we had poached eggs for brunch and it also came with Harissa, another great combination. You can also find it online on Amazon.
This is the Tunisian version of a frittata, quiche or tortilla. It is made with beaten eggs, grated cheese, meat and various vegetable fillings, and baked like a large cake. It is normally served as a free snack before meals in restaurants, but you can also buy it as a main dish.
Sweet, very sweet. The Tunisian version of American doughnuts. It is a round-shaped flour dough fried in oil and sprinkled with sugar or honey. They are delicious I must say, but you need to be prepared for a sugar boost.
It is highly recommended to eat them hot. So they will prepare it for you on demand, and then goes from the frying pot to your hand, with a quick sugar-loading stop.
Celtia is the main local beer (81% share). And it is quite good, especially for a country with low level of alcohol consumption. It is a light lager with a strong character.
You can find it in many hotels and restaurants, bottled or even on draught. But it is not everywhere. There are some alcohol-free areas. "Du Lac" (1 and 2), the so-called business district of Tunis, is one of them. It seems that the main investors are Saudis, and they would not allow it.
If you are looking to spend a full day in a resort, where you can enjoy a large pool and a few pints of Celtia, I recommend Carthage Thalasso Resort in Gammarth. It costs 60 TND on weekdays and 70 on weekends.
Thanks! Very useful advice, well written, honest & not trying to sell anything. Shouldnt be so hard to find but it is. You have very positively contributed to our stay in Tunis 🙂 from one travel writer to another!