Garner's Guide to Making Briefs More Persuasive: Tip 9 - Allow time for a full citation check of

Here's another tip from Bryan A. Garner's The Winning Brief: 100 Tips for Persuasive Briefing in Trial and Appellate Courts.

Don't discount the importance of the most mundane and common of paralegal tasks. Garner stresses that inaccurate citations are prejudicial to the interests of a client. He advises that someone other than the author of the brief check citations, and that they be painstaking in their review. 'Cold-checks' are best.

Garner claims that it takes only 15 seconds to confirm the case name, volume, page, and abbreviations of a legal citation are correct. (As opposed to 15 minutes in pre-online legal research service age.) While a tool like Lexis BriefCheck can expedite the process, this seems like an exaggeration to me. Perhaps legal citations that have been correctly entered will take no longer than 15 seconds. If a volume number is entered incorrectly, BriefCheck won't suggest a correction.

Garner does acknowledge that it may take "one full day" to check the legal and fact citations in a brief. Keep that estimate in mind the next time an associate gives you an impossible deadline!