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Universal Citation: North Carolina

A South Carolina focused guide to discussions of citation reform, sometimes referred to as vendor neutral citation, medium neutral citation, uniform citation, or public domain citation.

North Carolina Rule effective 2021

In December 2019, North Carolina adopted a citation rule requiring a hybrid format of traditional and universal citation, effective January 1, 2021.


The format contains these elements:

  1. case name
  2. traditional citation to:
    • volume number in the official reporter
    • first page in the official reporter
  3. universal citation to:
    • year
    • court
    • opinion number
  4. pinpoint paragraph number

Examples from the court's administrative order:

State v. Smith, 375 N.C. 152, 2020-NCSC-45, ¶ 16.
State v. Smith, 255 N.C. App. 43, 2020-NCCOA-118, ¶ 23.

Universal Citation for North Carolina

In June 2019, the Supreme Court of North Carolina sought comments on a proposal to adopt a universal citation format.

The proposal concludes with a list of expected benefits.

Universal citation would:
  • allow decisions to be posted online immediately, with permanent case and pinpoint citations
  • allow readers to more quickly and accurately identify source material in both electronic and hard copy formats, thanks to paragraph numbers; and
  • provide substantial savings of court staff time and taxpayer money—even though eliminating bound volumes was not proposed—while implementation costs are expected to be low.
p. 5, https://www.ncapb.com/wp-content/uploads/2019/06/Universal-Citation-for-North-Carolina.pdf

More Information on North Carolina

The North Carolina Appellate Practice Blog has posted information on the proposal and rule changes and may be a resource for further comments and updates as they become available.