Supreme Court Announces Adoption of Neutral Citation Form

Beginning on January 1, 2024, the Supreme Court of New Hampshire will add a neutral citation form (also referred to as public domain citation) to its published opinions.  Neutral citation is a form of case citation that is independent of a local or regional reporter.  The citation begins with the year issued, followed by the jurisdiction, and concludes with the opinion number.  For example, the first opinion of the court issued after January 1, 2024, will receive a citation of 2024 N.H. 1.

Opinions with neutral citation will include individually-numbered paragraphs.  To cite an opinion using neutral citation, the writer will refer to the paragraph that contains the proposition cited, rather than to the page.  Therefore, a full case citation will include the following: (1) the case name; (2) the year; (3) the jurisdiction (N.H.); (4) the opinion number for that year; and (5) the paragraph number(s).  For instance, if the information cited is contained in the fifth and sixth paragraphs of the opinion, the full citation would appear as follows: Kennedy v. Acme, Inc., 2024 N.H. 1, ¶¶ 5-6.  A short cite to the same material would be Kennedy, 2024 N.H. 1, ¶¶5-6. 

Opinions issued after January 1, 2024, will continue to be published in the New Hampshire Reports until further notice.  They will also continue to be posted to the Supreme Court of New Hampshire website.  During this period, the writer may continue to cite the New Hampshire Reports or may use neutral citation.  Adding the neutral citation form at this time not only enables opinions of the Supreme Court to be assigned a permanent citation immediately upon online issuance without waiting for the publication of an official paginated report, but also prepares for online issuance as the exclusive method of opinion publication.  See RSA 505:8, I.