11 J. App. Prac. & Process 191 (2010)
How Courts Use Wikipedia

handle is hein.journals/jappp11 and id is 193 raw text is: THE JOURNAL OF
APPELLATE PRACTICE
AND PROCESS
DEVELOPMENTS
HOW COURTS USE WIKIPEDIA
Joseph L. Gerken*
I. INTRODUCTION
The research for the present article began innocently
enough when a law student approached the reference desk and
asked, Can I cite Wikipedia in my moot court brieff This
author replied, confidently and authoritatively, Of course not.
Anybody can edit Wikipedia. Then, in an exercise of caution,
the author did a search in the ALLSTATES and ALLFEDS
databases of Westlaw.' To his surprise, he retrieved almost 200
opinions in which courts referred to Wikipedia. Since that
reference encounter several years ago, the number of cases
citing Wikipedia has doubled.
* Joseph L. Gerken is a reference librarian at the University at Buffalo Law Library. He
practiced law for over twenty years as an advocate for physically and mentally disabled
individuals and state prisoners. Mr. Gerken also clerked for Judge William M. Skretny of
the United States District Court for the Western District of New York. He has written a
number of articles on issues related to legal research as well as the book What Good is
Legislative History? Justice Scalia in the Federal Courts of Appeals (William S. Hein &
Co. 2007).
1. The query was simply: Wikipedia!
2. As of May 4, 2010, the opinions in at least 117 state and 326 federal cases include
citations to Wikipedia.
THE JOURNAL OF APPELLATE PRACTICE AND PROCESS Vol. 11, No. 1 (Spring 2010)

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