The Journal of The DuPage County Bar Association

Back Issues > Vol. 24 (2011-12)

Into the Public Domain: Making the Transition to Illinois’ New Citation Rules
by Anne K. Knight

Ah . . . the books.  To turn through the pages and watch the decades of decisions and developing legal precedent flip through your fingers. The nostalgia. But, alas . . . there’s the cost. We are well into the digital age and the Illinois Supreme Court has decided to follow suit, with a gentle nudge, no doubt, from state financial advisers. As of July 1, 2011, Illinois has joined approximately twelve other states in adopting a public domain citation system for State cases.[1] In adopting this system, the Court has eliminated the need for an official published reporter. [2]  This change is estimated to save the Illinois taxpayers hundreds of thousands of dollars every year.[3]  This savings appears to have made this move into the digital realm too enticing to pass up.

To effectuate this change, on May 31, 2011the Illinois Supreme Court entered Administrative Order 3140, amending “Supreme Court Rule 6, a commentary to Rule 6, Rule 23, and an administrative order under Rule 23.[4] Supreme Court Rule 6 governs citations and Supreme Court Rule 23 governs unpublished opinions.[5] The true wealth of information for these changes, however, comes from the additional Rule 6 commentary.[6] The commentary provides a detailed explanation of the new citation format as well as sample citations.[7]  Finally, the amendment to Rule 23 is simply a matter of providing a citation designator so the Rule 23 decision can be distinguished from the published opinions.[8]

So, what does this mean for you, the practitioner? First, you will not find any Illinois Reports (Ill. 2d), or Illinois Appellate Reports (Ill. App. 3d) books containing cases subsequent to July 1, 2011.[9] They simply do not exist. You will have to find the case elsewhere. Second, you are going to have to learn a new, but relatively simple, citation format.

Finding Cases. The new official report of an Illinois case decided after July 1, 2011 is not in a book, it is electronic.[10] The official opinions are all available at the Illinois Court Website.[11] Illinois cases have been available on the Courts’ website since 1996, but have not been citable from that location due to the existing citation rules.[12] From the Courts’ website Illinois cases are available under the “Documents” tab and in the “Quick Links” column on the left of the screen.[13] Recent decisions are posted in reverse chronological order and the earlier opinions are archived by year.[14] The unofficial hard cover reporters, however, will continue to publish the Illinois cases. Therefore, if you find yourself craving the crisp pages of a law book, you will be able to locate the cases in the North East Reporter (N.E.2d) and Illinois Decisions (Ill. Dec.).  And, of course, all of the cases will continue to be available in the commercial databases like Westlaw and LexisNexis.

Citation Format. Supreme Court Rule 6 now requires public domain citation for all “Illinois cases filed on or after July 1, 2011,” as well as Illinois cases that have been assigned a public-domain citation and were “not published in the Illinois Official Reports prior to that date.”[15] Further, when citing cases from another jurisdiction that has also adopted the public-domain citation format, one must use the public-domain citation format for that case as well.[16] Illinois cases published prior to July 1, 2011 will continue to be cited in the traditional manner. [17]

The basic public-domain citation format is simple. The first part of you citation is the case name; this is unchanged.  The case name is followed by the three part public-domain case designator number which consists of, (1) the year of the decision, (2) the court identifier, and (3) the court-assigned identifier number.[18] The court-assigned identifier number is the docket number for Supreme Court opinions and the last six digits of the docket number for Appellate Court opinions.[19] For example, Wirtz v. Quinn, 2011 IL 111903 was decided in 2011, by the Illinois Supreme Court (IL) and the docket number assigned by the court was 111903.  The court identifiers for the Illinois courts are as follows:

Supreme Court IL

First District Appellate Court IL App (1st)

Second District Appellate Court IL App (2d)

Third District Appellate Court  IL App (3d)

Fourth District Appellate Court  IL App (4th)

Fifth District Appellate Court  IL App (5th)[20]

With this new format, one can determine the proper citation by merely looking at the information inherent in every opinion. Additionally, it is not necessary to add the court and year in a parenthetical at the end of the citation as you would with a traditional citation,[21] because that information is readily discernable from the public-domain case designator number. In addition to the public-domain citation, one is permitted to add the parallel citations to the unofficial reporters.[22]

Pinpoint Citations. The only remaining matter for a standard public-domain citation is the pinpoint citation. Up until now, the pinpoint has always been the page number of the official reporter on which one could locate the cited material. This is no longer necessary or ideal as the official opinion is accessible in electronic format where page numbers are of limited importance and may change with program formatting.  The Court has adopted a pinpoint paragraph format.[23] Under this system, the public-domain case designator number is followed by the paragraph number or numbers in which the cited information can be found.[24] Rest assured however, you will not be required to diligently count twenty-five pages of paragraphs simply because you want to cite the second paragraph on the twenty-sixth page. As of July 1, 2011 the Courts have begun adding paragraph numbers to their opinions and Rule 23 Orders.[25]

At first blush, this change may seem an unnecessary frustration to some. Especially since the electronic opinions currently available from the court still have page numbers. But, after careful consideration, the benefits of pinpoint paragraphs are apparent. 

First, pinpoint paragraphs allow for more precise citation. Instead of citing to an entire page or several pages, you will be able to cite to the specific paragraph or paragraphs containing the pertinent information. Second, pinpoint paragraphs make it easier to locate cited material in “unofficial” sources. Prior to this change, it would be a real challenge to attempt to locate material in an unofficial source like the North East Reporter or Illinois Decisions, if one was only provide a pinpoint page for the official reporter. Doing so would require estimating which page the material would appear on in the unofficial reporter, or locating a headnote to guide you to the right location, if one exists.

Under this new system, the paragraph numbers will be consistent across the board because they are now a part of the opinion. So, paragraph 65 of a case in the official opinion on the Court website, is the same as paragraph 65 in the North East Reporter, which is the same as paragraph 65 in Illinois Decisions. 

A public-domain citation containing pinpoint paragraphs will look like this, People v. Scott, 2011 IL App (2d) 100990, ¶ 15.[26] If cited material covers multiple paragraphs one need only add an addition paragraph symbol and the span of paragraphs references; the citation would look like this: People v. Scott, 2011 IL App (2d) 100990, ¶¶ 15-18.[27]  Although it may require some getting used to, the pinpoint paragraph will likely be a positive change.

Other Case Designators. One of the common concerns raised about the change to public-domain formatting was with regard to Rule 23 Decisions. If published opinion and unpublished opinions are equally available on the same website, and both are given public-domain case designator number, how will we tell them apart? The Supreme Court has resolved this issue by requiring unpublished opinion to include the letter “U” immediately following the public-domain case designator number.[28] A Rule 23 Order will be cited like this: Bezanis v Fox Waterway Agency, 2011 IL App (2d) 100948-U.

The Court has created two additional identifiers for particular circumstances. First, opinions from the Appellate Court Workers’ Compensation Division will have a WC immediately following the court-assigned identifier number.[29] The citation will look like this: Jones v. Workers’ Compensation Comm’n, 2011 IL App (1st) 100234WC. Second, under circumstances in which a subsequent opinion is filed under the same docket number, for example, when the court reconsiders a matter after it has been remanded, a sequential capital letter will follow the court-assigned identifier number.[30] The citation to a subsequent opinion would be as follows: People v. Scott, 2011 IL App (2d) 100990-B. 

Conclusion. This concludes your crash course into the public-domain citations system, and the of the end of citations as you know them. Okay, that may be a little melodramatic, especially since all cases published prior to July 1, 2011 will continue to be cited in the traditional manner. Although, in truth, it is quite a shift from the standard format that has become second nature to so many of us. Getting used to this new system will be an adjustment, but in the end, I believe it will prove to be a superior system with a citation that provides more exact case information in more compact format.

[1]  Press Release, Ill. Sup. Ct., Ill. Sup. Ct. Announces New Pub. Domain Citation Sys., Ending Era of Printed Volumes (May 31, 2011) (on file with author) available at 

[2]  Id.

[3]  Id.

[4]  Ill. S. Ct., M.R. 3140 (eff. May 31, 2011).

[5]  Ill. S. Ct. R. 6 (eff. July 1, 2011); Ill. S. Ct. R. 23 (eff. July 1, 2011).

[6]  Ill. S. Ct. R. 6 cmt. (eff. July 1, 2011).

[7]  Id.

[8]  Ill. S. Ct. R. 23 (eff. July 1, 2011).

[9]  Press Release, Ill. Sup. Ct., Ill. Sup. Ct. Announces New Pub. Domain Citation Sys., Ending Era of Printed Volumes (May 31, 2011) (on file with author) available at


[11]State of Illinois, Welcome to the Illinois Courts (2011)

[12]Press Release, Ill. Sup. Ct., Ill. Sup. Ct. Announces New Pub. Domain Citation Sys., Ending Era of Printed Volumes (May 31, 2011) (on file with author) available at


[14]Id. at

[15]Ill. S. Ct. R. 6 (eff. July 1, 2011).


[17]Ill. S. Ct. R. 6.

[18]Ill. S. Ct. R. 6 cmt.



[21]See Id.

[22]Ill. S. Ct. R. 6.









Annie Knight is an associate at Walsh, Knippen, Knight  & Pollock, Chartered where she represents plaintiff’s in personal injury and medical negligence cases and practices some municipal law. She is also an adjunct professor at the College of DuPage where she teaches Introduction to Legal Research and Writing for the paralegal program. Prior to joining Walsh, Knippen, Knight & Pollock, Annie was a staff attorney with 18th Judicial Circuit Court.  As a staff attorney she conducted research and writing for the judges of the 18th Judicial Circuit. Annie obtained her undergraduate degree in psychology from the University of Illinois in 2002. In 2008, she received her law degree from Thomas Jefferson School of law in San Diego, California. While in law school she served as Co-Chief Notes Editor of Thomas Jefferson Law Review, and chair of the school’s Public Interest Law Foundation’s Career Committee.  Anne is also a 2008 winner of the Burton Award of Legal Achievement, a national legal writing award giving to fifteen law students each year.

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