Have you ever been searching in Westlaw or Lexis and experienced that wonderful moment when you finally locate the perfect case for your argument or the best law review for further research? Whether that moment occurred two minutes or a couple hours into your search, relief should set in, but all too often the most difficult and stressful part of research and writing has only begun: citing to your source in proper Bluebook format!
Well, fear no more! Your citation needs have finally been answered, or so touts Bestlaw designer Joe Mornin, a law student at UC Berkeley School of Law. Bestlaw is a Google Chrome extension, which can be installed from their site. Bestlaw adds functionality and citation assistance for WestlawNext.
Over the past few days, I have utilized this extension and realize there is great potential for this free support product, but that there are currently many limitations that prevent this from being truly revolutionary.
- Installation is very simple. Simply go to Bestlaw and click “INSTALL,” then click on the “Free” button. When in WestlawNext, the Bestlaw toolbar will be automatically visible whenever the application has a usable feature.
- Bluebooking is easy. Simply press the Tools tab in the Bestlaw toolbar, then “Copy Bluebook citation.” Then paste (control-v) the citation into the desired document.
- Currently, any citation to the United States Reports, Federal Reporter, and Federal Supplement are able to be placed into Bluebook format.
- The format of the citation appears to be correct, regardless of which reporter is being used. With over fifty citations checked, each one was correctly cited to the jurisdiction in proper formatting with the correct spacing and year.
- Nevertheless, the name of the case name was not correctly abbreviated each time. It appears that the case name is abbreviated according to how WestlawNext abbreviated the name when displaying search results. For instance, WestlawNext displays United States v. Laerdal Manufacturing Corporation as U.S. v. Laerdal Mfg. Corp. The result seems to be that Bestlaw’s full citation becomes U.S. v. Laerdal Mfg. Corp., 853 F. Supp. 1219 (D. Or. 1994). This is incorrect as United States should be spelled out in full when it is the entire name of the party. See Bluebook Rule 10.2.2. Additionally, Bluebook Rule 10.2.2 indicates that any word listed in table T6 should be abbreviated, even if it is the first word of the party’s name. Even so, Bestlaw does not properly cite Kiowa Tribe of Oklahoma v. Manufacturing Technologies, Inc., 523 U.S. 751 (1998), because it fails to abbreviate “Manufacturing” to “Mfg.”
- The toolbar allows a researcher to effortlessly copy the title, the citation, and/or the docket number at any time without having to scroll up or highlight.
- Full text copying is also available, which is a fantastic way to quickly copy the text (including working hyperlinks) into a word document.
- Sharing a document via email, Facebook, Twitter, or Google+ can occur in seconds with Bestlaw. This is a marked improvement from only having email or Kindle options without the extension.
- One useful feature is the ability to search the currently viewed case name within Court Listener, Cornell Legal Information Institute, Casetext, Google Scholar, and Wikipedia databases with a simple click of a button. The search will open up the desired database after it has run a search on the full citation of the case.
- Finally, the display functionality has been greatly expanded.
- There is a full screen tab for easier reading.
- A hyperlinked table of contents can be instantly created for efficient browsing of dense case opinions.
- A button to return to the beginning of an article, case, or statute has been created, as well as a key to move directly to the footnotes.
- Highlighting of search terms can be removed and added back to assist with ease of reading.
- Statute section can be collapsed, allowing only the beginning sentence of each section to be shown. This gives the researcher an efficient means of finding a desired section of a long statute without having to scroll or search for the particular section. Sections expand when clicked for complete reading.
- Bluebook citation is only available for reported federal case law. As of October 5, 2014, no state court or specialty court opinions have the ability to be cited by Bestlaw. Further no statutes, law review articles, treatises, encyclopedias, or any other type of document may be cited using Bestlaw. As this product was just released, further updates are expected to significantly improve this limitation.
- As stated above, the abbreviations of case names is not correct one hundred percent of the time. This is very problematic, as the number one driver of Bestlaw is its touted ability to help legal writers produce perfect Bluebook citations. Granted, the citation without the name has been flawless, but the full case name algorithm needs improvement.
- The Bluebooking function of Bestlaw only works with the most official citation. There does not appear to be a technique to include parallel citations.
- When having Bestlaw search Casetext, I have yet to use a case or article where Casetext actually runs the search. Currently, Bestlaw seems to only open up a search box on Casetext, but the researcher must formulate a search once it opens.
- Using the search keys to execute a search in either Court Listener, Cornell Legal Information Institute, Google Scholar, or Wikipedia results in the full case name and citation to be searched in the respective database. Often times, no results are found, but if either the case name or the citation would have been searched, the results would be more profitable.
- The statute sections being collapsible and expandable is a great idea for ease of finding the desired statute section, but it makes it very difficult to actually copy the section of text. Once expanded, any clicking on the text of a section results in collapsing that section. This results in only two ways of copying statutory text, both of which are undesirable. One approach is to begin to highlight the text in the margin and pull the cursor down within the margin without pressing on the text itself. Of course, this has the effect of having copied irrelevant text before and after the section that was intended to be copied. The other way is to disable the Bestlaw extension, which is a cumbersome process that defeats the very purpose of Bestlaw: increased functionality.
- Currently, Bestlaw is only available on the Google Chrome browser.
- For the two cases referenced above, Kiowa Tribe of Oklahoma v. Mfg. Techs., Inc., 523 U.S. 751 (1998), and United States v. Laerdal Mfg. Corp., 853 F. Supp. 1219 (D. Or. 1994), WestlawNext has a more complete Bluebook citation than does Bestlaw. Though it should be noted that these cases were chosen to highlight the limitations of Bestlaw, the unintended result was also showing instances where WestlawNext bested Bestlaw.
Bestlaw currently has many great features that make it worth getting. Particularly useful are the display features for readability and navigation. I have personally grown accustomed to the table of contents feature, and could not see doing research without it. Additionally, the ability to search outside WestlawNext regarding a case without having to open another browser tab and performing another search is extremely convenient. Plus of course, the price is right!
Even with the limitations on Bluebook citations, the extension is certainly helpful, with the only real annoyance coming from the difficulty in copying statutory text. Admittedly, Bestlaw is a work in progress. For that reason, there are links in the toolbar to send error reports and to suggest changes and improvements. The Bestlaw website also indicates that a version compatible with Mozilla Firefox is in the works, and that Bestlaw will work with Lexis in the future. Finally, Bluebooking will be expanded to include a wider variety of case law. Hopefully, the kinks in the case names abbreviations will also be fixed.
Overall, Bestlaw adds good value to WestlawNext. I recommend it now as is, but am truly excited for what is has the potential to become. However, until that potential is realized, proper knowledge and application of the Bluebook rules are still required! Good luck researching!