Build a citation you can explain

Opening problem

A draft passes its spellcheck. Every citation has italics. Yet one source does not support the sentence, two quotations changed words, and an id. now follows the wrong authority. A citation audit must inspect evidence, context, and format separately.

Learning objectives

Create a source inventory; test proposition support; review quotations and pinpoints; audit full and short citations; check receiving-document instructions; and verify automated output without overstating its reliability.

Five decisions, five audit questions

An audit runs the book's five decisions backward through a finished document. Begin with the sentence on the page, then recover the evidence and decisions that put it there. Give each answer its own record; a matching case name cannot answer a question about a holding.

Keep treatment and time visible across these questions. A source may be authentic and accurately quoted while the version needed for the dispute remains missing. Record that result as two observations: identity checked; relevant version unresolved. An unexplained “verified” would hide the second.

Annotated audit model

Draft sentence: The Brown opinion concludes that separate educational facilities are inherently unequal. Brown v. Bd. of Educ., 347 U.S. 483, 495 (1954).

The sentence reports an inspected historical conclusion. It does not claim a comprehensive current-law survey or court-specific filing compliance.

Build the inventory

List every real source used, its source type, full citation, access route, version, relied-on locations, and sentence/proposition. Identify duplicates so one authority appearing under several short names is not accidentally treated as several works. Keep fictional teaching sources conspicuously separate.

Save the source information needed to reproduce the check. For an opinion, record the opinion type and relevant page/paragraph context. For a statute, preserve title/code/provision/version. For record material, preserve document identity and required page mapping. For a web item, preserve title/date/version and direct URL.

Keep the research inventory separate from the copies you can share. A record may identify a licensed database item or restricted exhibit without authorizing its redistribution. Record its actual access route and preserve only the copies permitted for the work.

Read each sentence against its source

Underline the factual or legal proposition and compare it with the actual passage. Does the source state the claim, support an inference, provide an analogy, oppose it, or merely provide background? Choose the signal accordingly. Narrow an overbroad sentence rather than using a stronger signal to disguise the gap.

Check attribution. “The court held” differs from “the claimant argued.” Check temporal scope. “The 2024 Code lists” differs from “current law requires.” Check procedural scope. An assumed fact on a motion is not necessarily a trial finding. Check whether the pinpoint contains the material rather than merely the source's opening page.

For quotations, compare every word and punctuation mark against the inspected version. Review brackets, ellipses, capitalization changes, emphasis, and omission disclosures. A software comparison can flag differences; the substantive check must still determine whether a disclosed alteration preserves meaning. Check both the quote and the surrounding sentence's interpretation.

Review identification and context

Verify case names and reporter series, court/year information, statutory subdivisions, institutional authors, editions, and publication dates. Check full citations before short forms. Then review every id. in the final reading order. Paragraph movement and inserted authorities can break references that were previously correct.

Review source-specific eligibility for supra. Make sure a book short title distinguishes works by the same author. Confirm every index and chapter link reaches an actual destination. An internal navigation link is a usability check; it does not validate the cited legal proposition.

Receiving-document instructions

Identify the court, publication, instructor, or assignment. Read its current official requirements and any incorporated manual. Check local citation forms, footnotes, neutral or parallel citations, unpublished dispositions, record locators, word limits, and document formatting where relevant. Keep the requirements distinct from house preferences.

If instructions conflict, document the texts and their applicability before choosing. A specific receiving rule can supersede the book's general baseline for that document. If the apparent conflict cannot be resolved from authorized sources, mark it for review rather than quietly choosing whichever looks familiar.

Automated output

Citation generators and automated drafting systems can produce plausible nonexistent authorities, wrong series, incorrect pinpoints, fabricated quotations, and exaggerated holdings. A formatted output is a candidate citation. Identify the source independently, open it, and inspect the relevant passage. Do not cite a case merely because an automated answer supplies a confident summary.

Treat a search result as a retrieval lead. Match the opened document's caption, tribunal, date, and publication information before reading its passage. If the result is a different decision, record the mismatch and continue the search. A failed lookup is evidence about that lookup; it does not establish that the authority is nonexistent.

A practical audit order

First resolve nonexistent or unidentified sources. Next resolve unsupported propositions and quotation problems. Then check versions and treatment. Correct citation components and short forms after those substantive repairs. Apply receiving requirements and typography last. Finish by checking the exported document, where symbols, tables, links, and page breaks can change.

Do not spend the entire review polishing commas around an invented holding. Prioritize errors that change evidence and meaning. A reviewer should be able to distinguish a publication-ready typography issue from an unresolved authority issue.

Common mistakes and repairs

Compact reference

Inventory → source identity → passage/support → quotations → version/treatment → full citation → short forms → receiving requirements → typography/export. Keep each status and its evidence visible.

Write a repair ticket that another reader can use

Fictional training example — not legal authority. A two-paragraph memorandum contains four supplied defects: a case pinpoint has replaced its first page; a declaration is described as a judicial finding; an id. follows a newly inserted different authority; and an exhibit uses original page 1 even though the receiving instruction requires its ECF page 4. Treat these as four repair tickets rather than one instruction to “fix citations.”

A useful ticket has four parts: location, defect, repair, and closing check. “Paragraph 6: declaration called a finding; revise the attribution; compare the new subject and verb with the declaration” is actionable. “Citation needs work” is not. When the repair requires missing evidence, state that evidence rather than pretending the ticket is closed.

Keep the original sentence beside the proposed revision when a correction changes meaning. An author should be able to see that “all filings” became “this filing” or that “held” became “alleged.” A tracked comma correction rarely needs a research note; a changed legal proposition does.

Close a ticket only after testing its consequence. Restoring a source's identity may reveal that it contradicts the sentence. Correcting a quotation may require rewriting the conclusion. A new source can break the following short form. The closing check therefore reads the repaired sentence in context, not just the characters changed.

Follow a changed source through the argument

A source can support several sentences, and one sentence can depend on several sources. Record those relationships before large revisions. An edition change, a withdrawn opinion, a revised quotation, or a new receiving instruction can affect more than the citation where the change was first discovered. Searching for the source's full name alone may miss shortened names, id. references, and passages that quote it without repeating the title.

Fictional training example — not legal authority. An invented memorandum cites a code provision fully in paragraph 2, cites its subsection with Id. in paragraph 3, paraphrases it without a citation in paragraph 5, and summarizes it in a conclusion. A supplied amendment changes the exception relevant to the memorandum's time period. Updating only paragraph 2 leaves three dependent statements unexamined. The correct repair follows the proposition throughout the document and then rebuilds its citations in the final order.

Use a source-to-proposition list. Each row identifies the source and version, the relied-on passage, the document locations using it, and the narrow claim supported. When the source changes, the row gives a finite set of places to check. Include quotations and table entries as well as paragraphs. A table's short wording can conceal an overbroad rule just as readily as a sentence can.

Decide what must reopen

Use the kind of change to choose the next pass. A new edition reopens the passage and version checks. A different proposition reopens support and signal choices. A moved paragraph reopens id. and other context-dependent references. A different destination reopens receiving instructions. A punctuation-only edit usually needs a presentation check unless it changes a quotation, locator, or source identity.

Do not reopen every unrelated source simply to make the audit look larger. Follow the actual dependencies, record their locations, and inspect the changed result. Conversely, do not close the work after replacing the first full citation if the same proposition appears in the introduction, a table, and the conclusion.

Test the file that will leave your desk

Read the repaired document in its final order. Then open the exported file. Check section and paragraph symbols, italics, table continuity, page breaks, hyperlinks, and internal destinations. Compare any affected short form with its actual predecessor. The export is a new object to inspect even when the writing source was correct.

End the audit with a short scope record: sources and versions read; passages compared; receiving instructions applied; delivered file inspected; material questions still unresolved. Describe completed work specifically enough that the next reader can repeat it. The record is useful because it identifies evidence, not because it announces a universal assurance.

The Mata lesson: locate first, read next, polish last

In Mata v. Avianca, Inc., the court found that an attorney reviewed a colleague's submission for style, flow, and grammar without reading the judicial authorities it cited. The opinion separately recounts the opponent's report that many cited cases could not be located and that the few located cases did not support the asserted propositions. Those are three different checks: polished language, source existence, and source support. Mata v. Avianca, Inc., No. 22-cv-1461 (PKC), slip op. at 4–5 (S.D.N.Y. June 22, 2023), ECF No. 54, https://www.courtlistener.com/docket/63107798/54/mata-v-avianca-inc/.

Read that example within its limits. The opinion's introduction and later analysis discuss the respondents' conduct, warnings, and bad-faith findings; it is not a rule that every unsuccessful database query proves misconduct. The workshop uses the inspected historical findings, not an asserted current treatment history. The docket copy supplies the caption, date, document number, and printed pages used here.

Apply the five-question audit to the court's account. Identity required obtaining the cited decisions. Defining and locating support required reading their passages against the submission's claims. Presentation review addressed language and form. The failure was not that polishing had no value; the missing source work could not be supplied by polishing.

Fictional training example — not legal authority. Your source log contains: “Citation matcher: no result. Court docket: not searched. Draft sentence: Registry decisions always require a signed receipt.” The proper disposition is source unresolved; exclude from the supported draft pending retrieval. It is not “case proved fictitious,” because the search record is incomplete. Nor is it “keep citation because its punctuation looks right.” Search a suitable official collection or docket; inspect the actual decision if found; then test the universal word “always” against its reasoning. If the decision cannot be obtained, find other verified support or revise the claim.

Fictional training example — not legal authority. A second log says: “Opinion obtained. Page 8 states the claimant alleged receipt. Draft says the court found receipt.” Identity can now pass while support fails. The repair is a sentence attributing the allegation to the claimant, unless another inspected passage actually makes the finding. There is no need to discard an authentic source merely because the draft overstated it.

The five decisions now have visible outputs: identify the document; define the exact claim; locate the passage; construct a recoverable citation; test it beside the final sentence. Keep a failed search in the research log without promoting it into a finding about the universe of authority. Keep a successful lookup without promoting it into proof of a holding. Those boundaries make an audit informative enough to guide the next action.

Takeaway

Audit what the document claims, where the evidence is, and how a reader can recover it. Record the verification performed, including its limits.

Chapter source note

Source-specific conventions: Indigo 2.0 R1–R34. Brown, EX-001, majority at 495, supplies the historical audit model. The audit questions, repair tickets, and dependency method are original teaching material.

Judicial example: Mata v. Avianca, Inc., ECF No. 54, printed pages 1–5 and 25–34; the workshop uses findings at 4–5. The docket copy was retrieved through CourtListener and inspected October 8, 2026. No commercial citator or later-treatment check is claimed.